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SIGIR 

Special Inspector General for IRAQ Reconstruction 

For more information, contact SIGIR Public Affairs at 

(703) 428-1100 or PublicAffairs@sigir.mil Special Inspector General for Iraq Reconstruction 

Summary of Report: SIGIR 10-013 

Why SIGIR Did this Study 

According to the Under Secretary of Defense 

(Comptroller), since 2004, $3.74 billion has 

been allocated to the Commander’s Emergency 

Response Program (CERP) for Iraq, enabling 

military commanders to respond to urgent 

humanitarian relief and reconstruction 

requirements within their areas of responsibility. 

In July 2009, the Special Inspector General for 

Iraq Reconstruction (SIGIR) examined a hotel 

construction project at the Baghdad 

International Airport (BIAP) and identified a 

number of weaknesses in the project’s overall 

management by the Multi-National Corps-Iraq 

(MNC-I). These projects are now the 

responsibility of U.S. Forces-Iraq. Because of 

these weaknesses, SIGIR initiated a study of all 

of MNC-I’s CERP projects at BIAP. The cost 

of these projects totaled about $35.5 million as 

of November 2009. 

Our reporting objectives for the CERP-funded 

BIAP projects were to examine their (1) cost 

and outcome and (2) management. 

What SIGIR Recommends 

SIGIR recommends the following: (1) The 

Secretary of Defense should direct the Under 

Secretary of Defense (Comptroller) to revise 

CERP guidance to include a requirement that a 

project implementation plan be developed for 

large-scale projects; (2) the Commanding 

General, U.S. Forces-Iraq, should enhance its 

ongoing efforts for gaining additional benefits 

from the BIAP project investment by working 

with GOI officials to develop approaches for 

improving the use and sustainment of CERPfunded BIAP projects and, to the extent 

practicable, develop a plan for accomplishing 

any agreed-upon approaches for improving the 

use and sustainment of the projects; (3) the 

Commanding General, U.S. Forces-Iraq, should 

take actions to enhance its data systems used to 

track and record CERP project data. 

Management Comments 

USF-I agreed with SIGIR’s recommendation 

that it take actions to enhance its CERP project 

data systems. However, it did not agree that the 

Under Secretary of Defense (Comptroller) 

should revise CERP guidance to include a 

requirement that a project implementation plan 

be developed for large-scale projects. 

April 26, 2010 

COMMANDER’S EMERGENCY RESPONSE PROGRAM: PROJECTS AT 

BAGHDAD AIRPORT PROVIDED SOME BENEFITS, BUT WASTE AND 

MANAGEMENT PROBLEMS OCCURRED

WHAT SIGIR FOUND

After 4 years of effort and about $35.5 million in expenditures on 

46 projects, Multi-National Corps-Iraq’s (MNC-I) goals—to develop a 

commercial economic zone at the Baghdad International Airport (BIAP) that 

would generate revenue; provide prosperity, stability, and social 

development for the people of Iraq; and establish BIAP as an international 

gateway—have only been partially achieved. SIGIR notes that 22 projects 

valued at $19.3 million have had generally successful outcomes. However, 

24 projects valued at $16.1 million have had generally unsuccessful 

outcomes and these funds are at risk of being wasted without further action. 

SIGIR notes that MNC-I, now U.S. Forces-Iraq (USF-I) believed that 

improving the airport and stimulating economic recovery could help to 

reduce violence and contribute to the goals of the surge in U.S. military 

troop strength. To the credit of the current military command in Iraq, it is 

actively working with the GOI, which now has ownership of the facilities 

that were constructed, to identify opportunities to gain additional benefits 

from the investment that has been made. 

In general, MNC-I officials who managed the CERP projects followed the 

policies and procedures that were in place at the time. However, the 

outcomes of the projects raise questions about the overall adequacy of 

project management, particularly as it relates to the adequacy of guidance for 

implementing CERP projects. SIGIR identified five issues that contributed 

to management problems that were experienced, including: (1) the projects 

were undertaken without a plan to guide the effort and without adequate 

coordination with U.S. civilian agencies; (2) the projects were undertaken 

without a plan to evaluate the projects’ results and the impact on the level of 

violence in Baghdad; (3) CERP guidance in place at the time included 

management and oversight procedures designed for smaller, quick-reaction 

projects and did not fully address the management needs of large-scale 

counterinsurgency and economic development efforts; (4) MNC-I personnel 

assigned to the projects lacked expertise in large-scale development projects 

and rotated frequently, which contributed to oversight inefficiencies; and 

(5) project files were not well-maintained and project tracking data were 

incomplete. SIGIR also notes that project risk and outcomes were also 

impacted by (1) the inherent difficulties in undertaking projects in a war 

zone; and (2) difficulties in working with a government that is in the process 

of developing its own form of democracy and processes for governance. 

Over the past several years, DoD and MNC-I have significantly improved 

their management of CERP projects. Guidance improvements and recent 

changes to address the shortages of personnel who are trained in contracting 

officer’s representative and CERP-related responsibilities are particularly 

noteworthy. However, while these actions address some of SIGIR’s 

concerns about project oversight, gaps still remain with regard to planning. 

CERP guidance does not require project implementation plans. While this 

may be appropriate for small-scale CERP projects this is not the case for 

large-scale efforts with multiple integrated projects like the BIAP projects. 
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

400 Army Navy Drive • Arlington, Virginia 22202 

April 26, 2010 

MEMORANDUM FOR U.S. SECRETARY OF DEFENSE 

COMMANDING GENERAL, U.S. FORCES-IRAQ 

SUBJECT: Commander’s Emergency Response Program: Projects at Baghdad Airport 

Provided Some Benefits, but Waste and Management Problems Occurred (SIGIR 

10-013) 

We are providing this audit report for your information and use. It discusses a group of 

Commander’s Emergency Response Program projects undertaken at the Baghdad International 

Airport. We performed this audit in accordance with our statutory responsibilities contained in 

Public Law 108-106, as amended, which also incorporates the duties and responsibilities of 

inspectors general under the Inspector General Act of 1978. This law provides for independent 

and objective audits of programs and operations funded with amounts appropriated or otherwise 

made available for Iraq reconstruction and for recommendations on related policies designed to 

promote economy, efficiency, and effectiveness and to prevent and detect waste, fraud, and 

abuse. This audit was conducted as SIGIR Project 9026. 

We considered written comments from the U.S. Forces-Iraq when preparing this report. The 

comments are addressed in the report where applicable, and the letter is included in Appendix I. 

We appreciate the courtesies extended to the SIGIR staff. For additional information on the 

report, please contact David Warren, Assistant Inspector General for Audits, (703) 604-0982/ 

david.warren@sigir.mil or Glenn Furbish, Principal Deputy Assistant Inspector General for 

Audits, (703) 604-1388/ glenn.furbish@sigir.mil. 

Stuart W. Bowen, Jr. 

Inspector General 

cc: U.S. Secretary of State 

U.S. Ambassador to Iraq 

Commander, U.S. Central Command 

Administrator, U.S. Agency for International Development
Table of Contents 

Table of Contents i

Introduction 1

Background 1

Objectives 5

Many Projects Achieved Benefits, but Significant Investments Remain at Risk 

of Waste 7

Projects Resulted in Benefits and Potential Waste 8

Generally Successful Projects 10

Projects with Questionable Outcomes 17

Inadequate Planning, Staff Continuity, and Guidance Led to Questionable 

Outcomes 26

MNC-I Did Not Develop a Comprehensive Plan for the BIAP Projects 27

Project Coordination Was Informal and Not Well Documented 28

Measures to Assess Project Effectiveness Were Not Developed 30

Initial CERP Guidance Inadequate for Large-scale Projects 31

Lack of Expertise and Frequent Turnover of Personnel Led to Inefficiencies 32

MNC-I Project Data and Documents Were Incomplete and Limited Our Analysis 33

Conclusions, Recommendations, and Lessons Learned 35

Conclusions 35

Recommendations 36

Lessons Learned 36

Management Comments and Audit Response 38

Appendix A—Scope and Methodology 40

Appendix B—Summary of 46 CERP Projects at BIAP 44
Appendix C—MNC-I’s Official Explanation of the Development Effort 

 at BIAP 66

Appendix D—Approval Dates and Disbursements for CERP Projects 

 at BIAP 72

Appendix E—CERP Statutes 73

Appendix F—Permissible Categories of CERP Fund Usage 77

Appendix G—Acronyms 79

Appendix H—Audit Team Members 80

Appendix I—Management Comments and Audit Response 81

Appendix J—SIGIR Mission and Contact Information 93
1 

Commander’s Emergency Response Program: Projects at 

Baghdad Airport Provided Some Benefits but Waste and 

Management Problems Occurred 

SIGIR 10-013 April 26, 2010

Introduction 

According to Under Secretary of Defense (Comptroller), since 2004, $3.74 billion has been 

allocated to the Commander’s Emergency Response Program (CERP) for Iraq, enabling military 

commanders to respond to urgent humanitarian relief and reconstruction requirements within 

their areas of responsibility. In July 2009,1

 the Special Inspector General for Iraq Reconstruction 

(SIGIR) issued a report on a CERP project to construct a hotel at the Baghdad International 

Airport (BIAP). During that audit, SIGIR identified a number of weaknesses in the MultiNational Corps-Iraq’s (MNC-I) overall management of the project that raised questions about 

project selection, costs, oversight, management, and plans to transfer the hotel to the 

Government of Iraq (GOI). Because of these questions, SIGIR initiated a more comprehensive 

review of CERP projects at BIAP, including a collection of projects known as the BIAP 

Economic Zone (BEZ). The reported cost of these projects totaled about $35.5 million as of 

November 2009. 

Background 

CERP is governed by statutes, a financial management regulation, and other guidance. The 

statutes provide congressional direction and the funding level for CERP. The Department of 

Defense (DoD) provides detailed implementation guidance to commanders through the DoD 

Financial Management Regulation.2

 MNC-I, headquartered in Baghdad, Iraq, provided the 

overall program coordination for CERP in Iraq for the Multi-National Force-Iraq at the time 

these projects were undertaken. MNC-I and the Multi-National Force-Iraq were reorganized into 

U.S. Forces-Iraq (USF-I) on January 1, 2010. Therefore, USF-I is the current responsible 

command for addressing matters discussed in this report and provided comments on a draft of 

this report. However, in this report, we continue to refer to MNC-I and MNF-I as these were the 

organizations that approved and implemented these projects. MNC-I developed Money as a 

Weapon System (MAAWS), a policies and procedures manual for implementing CERP in Iraq. 

 

1 Commander’s Emergency Response Program: Hotel Construction Completed, but Project Management Issues 

Remain Unresolved, SIGIR 09-026, 7/26/2009. 2

 The Under Secretary for Defense (Comptroller) is responsible for the DoD Financial Management Regulation. 
2 

MAAWS provides additional guidance on the purpose of CERP and outlines a system of controls 

over the use of CERP funds, including instructions on program execution and project approval. 

As the CERP evolved, more requirements were added to the statutes for using the funds, such as 

establishing project approval and cost-sharing requirements. MNC-I updated the MAAWS and 

other CERP guidance as required to reflect these requirements. The regulations also provided 

direction on the types of CERP projects that are permissible. One category of permissible 

projects is “economic, financial, and management improvements.”3 Under this category, MNC-I 

officials developed a concept to renovate and expand the existing infrastructure at BIAP to 

provide facilities where international investors and humanitarian agencies could conduct 

business and meet with GOI officials in a secure environment. MNC-I’s concept was to make 

BIAP a gateway for international travel and improve economic conditions at BIAP to present a 

positive impression of reconstruction progress in the country. 

According to MNC-I officials, by improving the economic conditions at BIAP MNC-I would 

further a new strategy to help reestablish local governance, rebuild infrastructure, and revitalize 

the economy in Iraq. In December 2006, the Army issued a field manual on counterinsurgency 

that identified fundamental principles for achieving population security.4

 The manual identifies 

multiple tactics, including using money to conduct economic development activities to win the 

“hearts and minds” of the people. The manual encourages commanders to coordinate the 

projects with civilian U.S. agencies, but when those agencies are unable to coordinate military 

commanders may proceed on their own. 

Overarching Rationale and Approach to Projects 

MNC-I’s decision to undertake the projects at BIAP was also strongly influenced by rising 

violence in Iraq in late 2006 and early 2007. MNC-I believed that improving the airport and 

stimulating economic recovery could help to reduce violence and contribute to the goals of the 

surge in U.S. military troop strength. A paper written by MNC-I’s Chief of Civil-Military 

Operations describes MNC-I’s rationale for initiating the effort at BIAP (see Appendix C). The 

paper notes that Iraq lacked foreign investors to assist in its recovery and that bringing 

international investors to Iraq to meet with GOI officials could spur economic development. 

MNC-I saw the effort at BIAP as critical to the comprehensive counterinsurgency effort. The 

paper also notes that the counterinsurgency required MNC-I to “employ every tool available, to 

include economic initiatives, to give the people of Iraq a reason to turn away from violence and 

pursue a hopeful future.” The paper further notes that, taken in isolation, the counterinsurgency 

efforts were controversial and high risk but that the efforts were necessary “to turn the war 

around given limited funding sources and a very compressed timeline.” 

 

3

 See Appendix F for a complete list of CERP categories in the MAAWS. 

4

 Army Field Manual 3-24, Counterinsurgency, 12/2006.
3 

In written comments on a draft of this report, USF-I also explained that during the U.S. military 

surge in 2007 and 2008, the GOI provided significant ramp space and numerous facilities at 

BIAP for U.S. forces. To reciprocate, many CERP projects were initiated. According to USF-I, 

“the negotiated agreement can best be summarized as a stated commitment by U.S. Forces senior 

leaders to return the requisite space and facilities better than when they were received.” 

The CERP projects at BIAP were approved in phases from February 2005 through February 

2008. The main BEZ initiative consisted of four projects—a business center, a convention 

center, a hotel, and an office tower—intended to be used by for-profit businesses run by the Iraqi 

Ministry of Transportation (MOT). The other CERP projects at BIAP were intended to improve 

the airport and, in part, to enable BIAP to obtain International Civil Aviation Organization 

Airport Certification. This certification is a prerequisite for many international airlines to obtain 

insurance to land at an airport, which would enable more air traffic and greater economic 

development. These projects included renovation of an existing cargo terminal and the Iraq 

Aviation Institute; new construction of the Air Traffic Controller Training Center; and various 

other service, equipment, and utility projects. According to USF-I, many of the planned projects 

were impacted by the requirement to utilize existing property and infrastructure at BIAP. 

Site Layout 

Figure 1 illustrates the physical locations of 38 of the 46 individual CERP projects at BIAP. We 

visited most of these sites on September 28 and 29, 2009, and on November 16, 2009 we 

conducted a follow-up visit to observe the Business Center Security Building and the 

Transportation Operations Compound. Eight of the projects are not illustrated in Figure 1 

because six were service projects that did not correspond to a specific facility, such as engineer 

retainer contracts and a trash clean-up project; one was a mural painted on a concrete blast 

protection wall and only remnants are still on site, and one was for an airport signs project that 

we could not locate during our site visits. 
4 

Figure 1—Site Layout of 38 of the 46 Individual CERP Projects at BIAP 

Source: SIGIR update of briefing slide provided by 364th Civil Affairs Brigade (11/24/2009). 

Notes: (Numbers in parentheses are the number of projects at that location.) 

1-Convention Center (1) 11-Incinerators (1) 

2-Office Tower (1) 12-Drinking Water System (1) 

3-Caravan Hotel (1) 13-Electrical Generators (1) 

4-Business Center (9) 14-Loop Mural (1) 

5-Cargo Terminal (3) 15-Sewage System (1) 

6-Iraq Aviation Institute (6) 16-Storm Water Drainage System (1) 

7-Air Traffic Controller Training Center (1) 17-Culvert Lids (1); Runway Lighting System (1) 

8-Health Clinic (2) 18-Runway Scrape and Paint (1) 

9-Transportation Operations Compound (1); 

Trash Equipment (1) 

19-Air Traffic Control Center Standby Generator (1); 

 Uninterruptible Power Supply (1) 

10-Convenience Store and Coffee Store (1) 

Responsible Organizations 

BIAP is a Government-of Iraq (GOI)-owned facility funded by the MOT, which is responsible 

for airports and aviation in Iraq. The MOT assumed full control of BIAP on May 25, 2004. 

Previously, the airport in Baghdad was under the control of the Ministry of the Interior. Three 

entities within the MOT control airports and civil aviation: the Iraq Civil Aviation Authority 

(ICAA), which is responsible for civil aviation in Iraq and managing the country’s airports and 
5 

airspace; Iraqi Airways, which is the state-owned Iraq airline; and the Meteorological 

Department, which is responsible for weather observation. 

MNC-I was responsible for administering the CERP program in Iraq for the Multi-National 

Force-Iraq. Various civil affairs brigades under MNC-I conducted operations in support of 

MNC-I’s Civil Military Operations to promote GOI self-reliance, facilitate reconciliation, and 

assist efforts to improve civil and governmental capacity. Part of their responsibility was using 

CERP funds and projects to further these efforts. These brigades were responsible for initiating, 

executing, and overseeing CERP projects, including project management, during their time in 

Iraq: 5

U.S. Army 358th Civil Affairs Brigade February 2007 – November 2007 

U.S. Army 360th Civil Affairs Brigade November 2007 – August 2008 

U.S. Army 304th Civil Affairs Brigade August 2008 – April 2009 

U.S. Army 364th Civil Affairs Brigade April 2009 – January 2010 

The Convention Center, Office Tower, and Air Traffic Control Center Standby Generator 

projects were managed by the U.S. Army Corps of Engineers, Gulf Region Division for MNC-I. 

Headquartered in Baghdad, the Gulf Region Division provided engineering and construction 

services to the Multi-National Force-Iraq in support of military and civil construction through its 

division headquarters and one of its district offices (Gulf Region Central). The Gulf Region 

Division was inactivated on October 23, 2009 and replaced by the Transatlantic Division, 

headquartered in Winchester, Virginia. Gulf Region District remains the enduring district office 

in Iraq and is attached to U.S. Forces-Iraq. 

The U.S. Embassy Baghdad’s Transportation Attaché is the lead U.S. representative to the MOT 

and assists the GOI in developing its commercial airline industry. 

Objectives 

Our reporting objectives for the CERP-funded BIAP projects were to examine their (1) cost and 

outcome and (2) management. 

For a discussion of the audit scope and methodology and a summary of prior coverage, see 

Appendix A. For a summary of CERP projects at BIAP, see Appendix B. For information on 

MNC-I's rationale for developing BIAP, see Appendix C. For a timeline of project approvals 

and disbursements as of November 22, 2009, see Appendix D. For a list of CERP statutes, see 

Appendix E. For a complete list of MAAWS CERP categories, see Appendix F. For a list of 

 

5

 In total, 46 CERP projects were initiated at BIAP and are examined in this report. The overall effort at BIAP 

included a few of the CERP projects that were approved prior to the 358th Civil Affairs Brigade’s arrival in Iraq. 

We included these projects in our review because they were also intended to improve airport operations or enhance 

economic development. See Appendix D for the timeline for all CERP projects at BIAP. 
6 

acronyms used, see Appendix G. For the audit team members, see Appendix H. For a copy of 

the USF-I response to the draft report, see Appendix I. For the SIGIR mission and contact 

information, see Appendix J. 
7 

Many Projects Achieved Benefits, but Significant 

Investments Remain at Risk of Waste 

As of November 2009, MNC-I had approved and initiated 46 individual CERP projects at BIAP 

at a total cost of about $35.5 million. About $19.3 million (54%) of the total expenditures 

involved 22 projects that resulted in successful outcomes. However, about $16.1 million (46%) 

was used for 24 projects that resulted in outcomes with questionable value; those funds may be 

wasted unless steps are taken to improve the maintenance and use of the projects. Overall, these 

projects were intended to develop an economic zone and improve the operations of the airport; 

they consisted of various construction projects, service projects, equipment purchases and repair 

projects, and projects to renovate or repair utility systems. The successful projects included 

facility construction (48%), installation or repair of utilities (15%), purchase of equipment 

(17%), and management services (20%). The projects with questionable outcomes were largely 

facility construction (70%) and equipment purchases (25%). 

To determine project costs and outcomes, we analyzed disbursement data from the Standard 

Finance System (Army) and the U.S. Army Corps of Engineers’ Financial Management System 

and additional cost and project schedule data from documents in the CERP project files, such as 

project cost estimates, initial purchase request forms, contracts, statements of work, bills of 

quantities, notices to proceed, invoices, receiving reports, and payment documents. We also 

conducted two site visits. On September 28 and 29, 2009, we visited most of the project sites, 

and on November 16, 2009, we conducted a follow-up site visit to the Business Center Security 

Building and the Transportation Operations Compound. The projects we visited encompassed 

34 of the individual CERP projects and about $29 million spent at BIAP. During site visits, we 

interviewed GOI officials who happened to be at the project sites during our visit. 

To present our analysis, we grouped the projects into two categories: those that were generally 

successful and those that had questionable outcomes. Overall, the generally successful projects 

are being used as intended. They have been completed, transferred to the GOI, and are being 

mostly sustained by the GOI. We also included one-time service contracts in the generally 

successful category where appropriate. The questionable outcome projects include projects that, 

at present, are not being used by the GOI, have not been maintained, are being used minimally or 

not as intended, or were terminated before completion. We also questioned the outcomes of 

projects where the project files contained minimal evidence of work performed. Where 

applicable, we took into account the results of third-party assessments that were related to the 

projects; we did not conduct independent engineering assessments to verify the third party 

assessments. Not all of the project files were complete, so we had to rely on testimonial 

evidence regarding project completion, transfer, and sustainment for some projects. When the 

preponderance of the available evidence suggested that project outcomes were favorable, we 
8 

categorized the projects as generally successful. In light of these limitations, we believe our 

categorizations are reasonable given the available evidence. 

We acknowledge the overall MNC -I rationale for the BIAP projects was to reduce violence and 

to support the objectives of the military surge. We did not attempt to assess the project outcomes 

based on that rationale because such an analysis would require us to make military judgments 

that are not in the scope of our audit responsibilities or capabilities. However, we do note that 

MNC-I senior officials stated that overall the BIAP projects contributed to achieving those 

objectives.6 At the same time, we believe that opportunities still exist to gain greater benefits 

from the investment. 

Projects Resulted in Benefits and Potential Waste 

The total reported cost of the 46 individual CERP projects at BIAP was about $35.5 million as of 

November 2009. The work included 16 construction projects to build or renovate facilities, 

13 service projects such as managing a business center or providing temporary air traffic 

controllers, 14 projects to purchase or repair equipment, and 3 projects to renovate or repair 

utility systems. These projects, approved between February 2005 and February 2008, ranged in 

cost from $7,600 for airport signs to about $5.7 million for the renovation of two former 

terminals to serve as a convention center. The average cost of the 46 projects was $770,758. 

Figure 2 shows the costs of the 46 projects by project type. 

 

6

 According to the senior MNC-I military official, the GOI permitted MNC-I to use the property and buildings at 

BIAP to support a combat aviation brigade, which facilitated the military surge; the CERP projects were funded, in 

part, to recognize the GOI’s contribution to the war effort. 
Figure 2

(by proj

Source: SIG

Twenty-t

projects r

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2—Reporte

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GIR analysis of S

two of the pr

resulted in o

nstruction

20,568,001

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Standard Financ

rojects were 

outcomes of q

58%

of 46 Indivi

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 completed a

questionable

Uti

$2,91

8%

9 

dual CERP

) and MNC-I and

and were gen

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ility

12,400

Se

$4,6

Eq

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P Projects 

d GRD data (11/

nerally succ

ervice

630,883

quipment

$7,343,586

at BIAP 

/22/2009). 

essful; however, 24 of the 
10 

Generally Successful Projects 

Figure 3 shows the costs of the 22 generally successful projects by project type as of 

November 22, 2009. 

Figure 3—Reported Costs of the 22 Projects with Generally Successful 

Outcomes (by Project Type) 

Source: SIGIR analysis of Standard Finance System (Army) and MNC-I and GRD data (11/22/2009). 

Table 1 lists the 22 generally successful projects, their project type, approval date, outcome, and 

cost. These projects represent about 54% of total CERP costs at BIAP. 

Table 1—22 CERP Projects with Generally Successful Outcomes (as of 

11/22/2009) 

Name Project Type 

Approval 

Date Outcome Cost

Office Tower Construction 04/2007 Renovation 

completed 

and used as 

intended 

$4,238,552 

Caravan Hotel Construction 10/2007 Construction 

completed 

and used as 

intended 

$4,164,588 
11 

Name Project Type 

Approval 

Date Outcome Cost

Transportation Operations 

Compound 

Construction 02/2008 Renovation 

completed 

and used as 

intended 

$487,590 

Convenience Store and 

Coffee Shop 

Construction 08/2007 Renovation 

completed 

and used as 

intended 

$179,000 

Health Clinic Renovation Construction 11/2006 Renovation 

completed 

and used as 

intended 

$160,500 

Business Center Security 

Check Point 

Construction 07/2006 Construction 

completed 

and used as 

intended 

$42,594 

Electrical Generators Equipment 06/2007 Repaired and 

used as 

intended 

$1,457,641 

Trash Equipment Equipment 04/2007 Provided and 

used as 

intended 

$1,430,757 

Health Clinic Equipment Equipment 06/2007 Provided and 

used as 

intended 

$363,574 

Uninterruptible Power Supply 

at Air Traffic Control Tower 

Equipment 12/2006 Provided and 

used as 

intended 

$47,547 

Airport Signs Equipment 02/2005 Provided and 

used as 

intended 

$7,600 

Air Traffic Controllers 

Replacement 

Service 08/2007 Service 

provided 

$1,655,667 

Loop Mural Service 08/2007 Service 

provided 

$900,000 

Trash Clean-Up Service 10/2006 Service 

provided 

$350,000 

T-Wall Mural Service 05/2007 Service 

provided 

$280,000 

Engineering Study for BIAP 

Sewer, Water, Electric and 

Storm Water 

Service 07/2007 Service 

provided 

$252,000 
12 

Name Project Type 

Approval 

Date Outcome Cost

Business Center 

Management Contract II 

Service 12/2007 Service 

provided 

$211,200 

Business Center 

Management Contract I 

Service 12/2006 Service 

provided 

$142,840 

Fire System Test Service 04/2007 Service 

provided 

$23,800 

Drinking Water System Utility 08/2007 Repair 

completed 

and used as 

intended 

$1,731,050 

Sewage System Utility 08/2007 Renovation 

completed 

and used as 

intended 

$836,350 

Storm Water Drainage 

System 

Utility 05/2007 Renovation 

completed 

and used as 

intended 

$345,000 

Total $19,307,850

Source: SIGIR analysis of Standard Finance System (Army) and MNC-I and GRD data (11/22/2009). 

These five projects are examples of projects with generally successful outcomes: 

Office Tower 

Outcome Summary: Renovation Completed, Transferred, Mostly Sustained, and Used as 

Intended 

At a reported cost of about $4.2 million, the Office Tower renovation was initiated in April 2007, 

completed on June 30, 2008, and transferred to the GOI on January 20, 2010, nearly 19 months 

after the project was completed. A private company has been operating the office tower for the 

GOI since October 2008. The management contract does not involve CERP funds, but MNC-I 

negotiated the management contract between the private company and the GOI because the 

management contract promotes project sustainment by providing the GOI steady revenue and 

helps to ensure that the facility is used as intended. 

The initial U.S. investment resulted in some private investment and has enhanced professional 

opportunities for people in Iraq; however, the venture has not generated a net profit. From 

January through September 2009, the office tower has operated at a net loss to the private 

management company, mainly due to security expenses paid to a subcontractor and the salaries 

paid to employees. As of November 2009, the office tower was just about 64% leased. Private 
13 

investors who rented a floor in the tower stated that their company offers the only facility in Iraq 

where students can obtain international information technology certifications. We toured the 

office space and noted that it offers modern training equipment, which allows classes to be led 

by instructors from all over the world via satellite. An executive officer for the company stated 

that most of the students who attend training at the facility are Iraqi, and many work either for 

the GOI or for multinational companies. Figures 4 and 5 are examples of the office space in the 

office tower. 

Figure 4—Office Tower Interior 

 

Source: SIGIR photographs taken during site visit on 9/28/2009. 
14 

Figure 5—Remodeled Office Space and Computer Lab Independently Funded by 

Office Tower Tenant 

Source: SIGIR photographs taken during site visit on 9/28/2009. 

Replacement Air Traffic Controllers 

Outcome Summary: One-time Service Provided. 

This project was completed at a reported cost of $1,655,667. As the air traffic to BIAP increased 

in 2007, the GOI faced a serious shortage of certified air traffic controllers to handle the 

increased civil air traffic at BIAP. Therefore, MNC-I initiated the Air Traffic Controller 

Replacement Project in July 2007 to provide four temporary civilian air traffic controllers for the 

BIAP control tower to replace Iraqi controllers, for 1 year, while they received advanced training 

to manage the increased workload. The justification documents for the award sufficiently 

explained the urgent requirement that necessitated limiting competition and at least two 

contracted air traffic controllers reported to work in November 2007 to meet this need. 

Trash Equipment 

Outcome Summary: Provided, Transferred, Mostly Sustained, and Used as Intended 

This project was initiated in April 2007 at a reported cost of $1,430,757; it included the purchase 

of trash equipment and construction of a trash transfer station. The trash equipment was 

purchased and appeared to have been used regularly; thus, we categorized the project as 

generally successful. The trash transfer station, however, appeared not to have been used for its 

intended purpose, which was to serve as a collection point for the incinerators. When we visited 

the transfer station in September 2009, we observed smoke stains on the cement bins of the 

transfer station, which appeared to have been caused by using the bins to burn trash. According 
15 

to MNC-I officials, burning trash in this manner is a standard practice throughout Iraq. Figure 6 

shows an example of the trash equipment and the trash transfer station. 

Figure 6—Trash Equipment and Trash Transfer Station 

Source: SIGIR photographs taken during a site visit on 9/28/2009. 

Loop Mural 

Outcome Summary: One-time Service Provided 

Initiated in August 2007, this project commissioned Iraqi artists to paint a mural on the wall that 

borders the access road to BIAP. The mural, which cost a reported $900,000, was intended to 

reflect, in a progressive nature, historical and economic development themes. The concept was 

to provide patrons who are driving along the access road scenes that represent the transition of 

the Iraqi economy and to offer a perspective of future economic development. Two of the 

mural’s specifications included a total distance of 4,000 meters long by 4 meters high and paint 

that would hold up under direct sun and other environmental conditions. 

A written statement (see Appendix C) describing MNC-I’s rationale for the BIAP projects 

includes this statement regarding the loop mural: 

As MNC-I worked to get BIAP “open for business” through its minimalist work 

on the BIAP Economic Zone, the Corps felt an imperative to do something to 

beautify this 2.3 mile wall, the first and last impression of every civilian entering 

or departing Baghdad via air. For $900K total, artists were hired to beautify this 

over two mile stretch with a mural highlighting Iraqi culture and hope; this 

seemed a very fair price to make an urgent statement that hope existed in Iraq. 
16 

We viewed the mural from vehicles as we were transported to and from other project sites during 

our site visit in September 2009; however, we did not get close enough to determine whether the 

mural had been sealed.7

 The mural is painted on a cement wall that lines the main road wrapping 

around the airport. We noted that the mural wall had indications of surface deterioration. For 

example, in some instances the surface had chipped away and the underlying brick was exposed. 

Also, compared to images in the project files, the vividness of the color appeared to have faded 

since the mural was painted in 2007. MNC-I officials stated that the mural served its intended 

purpose; however, it is unclear what impact the mural had. Figure 7 shows two sections of the 

mural. 

Figure 7—Loop Mural 

Source: SIGIR photographs taken during site visit on 9/28/2009. 

T-Wall Mural 

Outcome Summary: One-time Service Provided 

This project was initiated in May 2007. Similar to the loop wall mural, the purpose of the T-wall 

mural was to beautify BIAP and to reflect hope. Unlike the loop wall mural, the T-wall mural 

was painted on temporary T-walls, at a reported cost of $280,000, which surrounded the 

convention center and adjacent buildings. During our site visit on September 28, 2009, we 

observed remnants of the T-wall from the roof of Hall 1 of the convention center (see Figure 8 

right panel). 

 

7

Because of security concerns, vehicles are not allowed to stop on the airport entrance road. 
17 

It is unclear whether these murals had any impact on potential investors travelling to and from 

BIAP; however, the project was intended to be a temporary art installation and, as such, it 

appears to have been used as intended. 

The Figure 8 left-panel photograph was taken from the project files and the right-panel 

photograph was taken by SIGIR. 

Figure 8—Temporary T-Wall Mural 

Source: Photograph from project file taken on 6/25/2007 and SIGIR photograph taken during site visit on 9/28/2009. 

Projects with Questionable Outcomes 

Twenty-four projects, including four projects discontinued for various reasons, resulted in 

questionable outcomes. USF-I questions SIGIR’s assessment of 6 of these projects, and SIGIR 

has requested additional information on the projects’ status. Figure 9 shows the reported costs of 

24 projects with questionable outcomes by project type as of November 22, 2009. 
18 

Figure 9—Reported Costs for the 24 Projects with Questionable Outcomes 

(by Project Type) 

Source: SIGIR analysis of Standard Finance System (Army) and MNC-I and GRD data (11/22/2009). 

Table 2 lists the 24 projects with questionable outcomes along with the project type, approval 

date, outcome, and cost. These projects represent about 46% of total CERP costs at BIAP. 

Table 2—24 CERP Projects with Questionable Outcomes (as of 11/22/2009) 

Name Project Type 

Approval 

Date Outcome Cost

Convention Center Construction 01/2007 Renovation 

partially 

completed, 

contracts 

terminated 

$5,725,380 

Cargo Terminal 

Refurbishment 

Construction 08/2007 Renovation 

completed, used 

minimally and not 

maintained 

$1,958,792 

Air Traffic Controller Training 

Center 

Construction 08/2007 Construction 

completed, used 

minimally 

$1,788,045 

Iraq Aviation Institute Access 

Road and Parking Lot 

Construction 04/2007 Construction 

completed, used 

minimally 

$1,041,648 
19 

Name Project Type 

Approval 

Date Outcome Cost

Iraq Aviation Institute 

Rehabilitation 

Construction 10/2006 Renovation 

completed, used 

minimally 

$398,502 

Business Center Building 

Renovation 

Construction 11/2006 Renovation 

completed, not 

being used 

$168,550 

Culvert Lids Construction 02/2005 Minimal evidence 

of work 

performed 

$90,000 

Iraq Aviation Institute Facility 

Improvement 

Construction 04/2007 Renovation 

completed, used 

minimally 

$79,735 

Business Center Security 

Building Rehabilitation 

Construction 11/2006 Renovation 

completed, not 

being used 

$31,250 

Iraq Aviation Institute Water 

Supply Pipe 

Construction 11/2007 Construction 

completed, used 

minimally 

$13,275 

Incinerators Equipment 06/2007 Provided, not 

being used 

$2,939,896 

Cargo Terminal Additional 

Equipment 

Equipment 02/2008 Provided, not 

maintained 

$400,965 

Iraq Aviation Institute 

Automation Contract 

Equipment 04/2007 Provided, used 

minimally 

$186,493 

Air Traffic Control Tower 

Standby Generator 

Equipment 09/2005 Repaired, not 

maintained 

$128,000 

Iraq Aviation Institute 

Furniture Purchase 

Equipment 04/2007 Provided, used 

minimally 

$112,138 

Business Center Automation 

Contract 

Equipment 11/2006 Provided, not 

being used as 

intended 

$89,000 

Business Center Furniture 

Contract 

Equipment 11/2006 Provided, not 

being used as 

intended 

$82,804 

Runway Lighting System Equipment 01/2008 Provided, not 

maintained 

$72,856 

Business Center Equipment 

Purchase 

Equipment 04/2007 Provided, not 

being used as 

intended 

$24,315 
20 

Name Project Type 

Approval 

Date Outcome Cost

Cargo Terminal Automated 

Inventory System and 

Management Contract 

Service 08/2007 System 

purchased but 

license 

agreement not 

signed, 

management 

contract 

terminated 

$459,996 

Runway Scrape and Paint Service 01/2008 Service partially 

provided, project 

terminated 

$177,870 

Engineer Retainer Contract II Service 06/2007 Minimal evidence 

of work 

performed 

$98,000 

Engineer Retainer Contract I Service 11/2006 Minimal evidence 

of work 

performed 

$61,590 

Business Center Internet 

Service 

Service 10/2007 Service partially 

provided, project 

terminated 

$17,920 

Total $16,147,020

Source: SIGIR analysis of Standard Finance System (Army) and MNC-I and GRD data (11/22/2009). 

The following five projects are examples of projects that had questionable outcomes: 

Convention Center 

Outcome Summary: Renovation Partially Completed, Project Terminated. 

Since the project was initiated in January 2007, the U.S. government has spent a reported 

$5.7 million8

 on the convention center. The purpose of the project was to renovate two old 

terminal buildings to be used as convention center halls at BIAP. The project consisted of two 

contracts, both of which were awarded by GRD on behalf of MNC-I.9

• The first contract, for $5.46 million, was awarded in January 2007. The contract was 

modified during the demolition phase to compensate for unforeseen site conditions—the 

discovery of asbestos and bird feces—which raised the price to about $6.4 million. After 

 

8

 In addition to the costs paid to the contractor, the total cost reflects administrative costs paid to GRD for 

administering the contract. 

9

 A third contract to complete the renovations and manage the Convention Center was never awarded because the 

ICAA and the MOT could not agree on the terms of the contract. 
21 

about $4.5 million was spent, the contract was terminated for default in November 2008 

because the contractor failed to perform contractual obligations. 

• The second contract, for $1.39 million with funds deobligated from the first contract, was 

awarded in March 2009. It was terminated for convenience in September 2009 after 

about $228,000 had been spent because negotiations between MNC-I and GOI for the 

management contract broke down. The ICAA and the MOT could not agree on the 

contract for managing the facility upon completion. Also, before the negotiations for the 

management contract dissolved, the GOI did not provide the contractor access to the 

project site because it was dissatisfied with the contractor’s performance on previous 

projects. MNC-I decided not to spend additional funds on the project because it believed 

the GOI would not be able to sustain the project without a management contract in place. 

MNC-I directed GRD to terminate the contract for convenience. 

The two contracts that were awarded did not include requirements to connect the convention 

center to the main power supply. At the time the convention center project was planned and 

approved, a separate project had been approved to improve the main power supply at BIAP. The 

statement of work for the convention center was written on the basis that the electrical project 

would have been completed and would have addressed the electrical supply needs for the 

convention center. Because the electrical power project was later cancelled, additional work—

beyond what was included in the contracts’ statement of work, would have been necessary to 

make the convention center buildings operational. 

After the second contract was terminated, the ICAA placed security guards at the convention 

center; nevertheless, some equipment stored there disappeared. For example, an inventory taken 

in 2009 showed that 60 boxes of florescent bulbs were removed from the site. To prevent further 

loss, MNC-I officials moved the equipment to a U.S. government storage site near BIAP. The 

intent was to secure the equipment so that it could be reallocated to other CERP projects or be 

used elsewhere. During November 2009, the excess equipment was being transferred to the 

Defense Reutilization and Marketing Service site near BIAP. Once the equipment is turned over 

to the Defense Reutilization and Marketing Service facility, it will be reused, transferred, 

donated, sold, or disposed of. 

When we visited the project site in September 2009, we observed that both buildings required 

significant work and had not yet been transferred to the GOI. Nevertheless, two events were 

held in the unfinished Hall 1 of the convention center in late 2008, and a third was held in 

December 2009. MNC-I officials estimated that one of these events, a 3-day oil exposition held 

in December 2008, generated about $1 million in revenue. Power for this event was provided by 

running a temporary line from the electrical substation in Hall 2 to Hall 1 and by using a small 

generator provided by the contractor who ran the event. Potential investors have repeatedly 

expressed interest in holding events at the convention center; according to a senior USF-I 

military official, in February 2010 a Japanese delegation was specifically interested in the 
22 

facility. USF-I officials told us that they did not plan to spend additional funds on the 

convention center and transferred it to the GOI on January 20, 2010. Figures 10 and 11 show the 

condition of the convention center as of September 28, 2009. 

Figure 10—Convention Center Hall 1, Exterior and Interior 

Source: SIGIR photographs taken during site visit on 9/28/2009. 

Figure 11—Convention Center Hall 2, Exterior and Interior 

Source: SIGIR photographs taken during site visit on 9/28/2009. 

In written comments on a draft of this report, USF-I said that management of the convention 

center project transferred between civil affairs brigades in February 2008. The subsequent 

assessment of the contract that led to its termination was executed after this transfer. 
23 

Incinerators 

Outcome Summary: Provided, Not Being Used 

The project was initiated in June 2007 to install incinerators at BIAP. Two incinerators were 

purchased and installed at a cost of about $3 million. The project was transferred to the ICAA in 

May of 2008. On September 28, 2009, we observed that the fuel tank was empty and confirmed 

that the incinerators appeared not to have been used recently. SIGIR asked a senior GOI official 

why the incinerator was not used and he stated that Iraqis do not use incinerators, raising 

questions about project coordination with the GOI. Because the incinerators are not being used, 

SIGIR considers the $3 million spent on this project to be wasted. Figure 12 shows the 

incinerators. 

Figure 12—Incinerators 

Source: SIGIR photographs taken during site visit on 9/28/2009. 

Cargo Terminal Projects 

Outcome Summaries: 

• Cargo Center Refurbishment: Renovation Completed, Used Minimally, Not Maintained 

• Cargo Terminal Automated Inventory System and Management Contract: System 

Purchased but License Agreement not Signed; Management Contract Terminated 

• Cargo Terminal Additional Equipment: Provided but Not Maintained 

The cargo terminal was to be renovated through three CERP projects costing about $2.8 million. 

One contract for all three projects was awarded to a single contractor. The original contract, 

signed in September 2007, included two projects: the initial renovation project and a project to 
24 

provide an automated inventory system, which included a management contract to run the 

system. According to documents in the project file, MNC-I split the overall project into two 

bidding processes because the renovation and inventory management system required very 

distinct services. Specifically: 

The renovation work requires a construction company with renovation, 

construction, and equipment repair skills; while the management project requires 

a company with international air freight expertise with knowledge of automated 

cargo management systems. Although both projects were awarded to one 

company, the management will be sub-contracted to a qualified company with 

vast knowledge and experience with international air freight operations. 

Later an “increase in funds” project was added in February 2008. This project provided 

additional equipment that was not included in the original contract, such as high-loaders, a 

potable water station, and a fan for the ventilation system. 

During our site visit on September 28, 2009, we observed that the cargo terminal was in a state 

of disrepair and garbage was strewn about. Some of the equipment purchased with U.S. funds 

seemed never to have been used or appeared damaged. For example, a generator and a forklift 

were still wrapped in their original plastic covering, and the generator appeared never to have 

been used. The large metal doors of the cargo terminal, which had been repaired as part of the 

original project, were damaged to the point that they were not operational. 

Additionally, Iraqi officials on site confirmed that computers were purchased to run the 

automated inventory system, but the inventory system currently used at the cargo terminal is 

manual. Evidence in the project file indicates that the management project was de-scoped from 

the cargo terminal contract because Iraqi Airways refused to sign a licensing agreement with the 

cargo inventory system providers. Figure 13 shows the interior of the cargo terminal. 
25 

Figure 13—Cargo Terminal Interior 

Source: SIGIR photographs taken during site visit on 9/28/2009. 

See Appendix B for a discussion of all 46 CERP projects at BIAP. 
26 

Inadequate Planning, Staff Continuity, and Guidance 

Led to Questionable Outcomes 

In general, MNC-I officials who managed the CERP projects at BIAP followed the policies and 

procedures that were in place at the time the projects were undertaken. However, gaps in those 

policies and procedures allowed the projects to move forward with less than adequate 

management controls. These gaps contributed significantly to the questionable outcomes and 

potential waste identified in the previous section. As the BIAP projects were being undertaken, 

MNC-I was significantly improving its guidance on managing CERP funds,10 and the majority of 

the management issues we identified have been addressed by these guidance changes. 

Nevertheless, the changes do not address the management of long-term projects and the type of 

management controls that need to be in place as project responsibility is handed from one unit to 

another. 

Several issues contributed to the questionable outcomes of the CERP projects at BIAP: 

• The projects were undertaken without a comprehensive plan to guide the effort, and 

without adequate coordination with U.S. civilian agencies. (Better coordination is now 

required by MAAWS, but comprehensive plans are not required.) 

• The projects were undertaken without establishing a basis for evaluating the projects’ 

economic and military impacts. (MAAWS now requires metrics.) 

• CERP guidance, in place at the time, used management and oversight procedures 

designed for smaller, quick reaction projects and did not fully address the management 

needs of large-scale counterinsurgency and economic development efforts. (Guidance 

has improved but still focuses on individual projects.) 

• MNC-I personnel assigned to the projects lacked expertise in large-scale development 

projects and rotated frequently, which contributed to oversight inefficiencies. (This 

remains an area of concern.) 

• Project files were not well-maintained and project tracking data was incomplete. (This 

continues to be a long-standing problem that USF-I stated that it is aware of and is 

working to correct.) 

 

10 For example, for higher cost projects, the January 2009 MAAWS requires commanders to document coordination 

with provincial reconstruction teams; secure GOI commitment to sustain the projects, including providing for 

operations and maintenance costs; establish performance objectives and monitor progress; and develop cost-sharing 

arrangements with the GOI. 
27 

MNC-I Did Not Develop a Comprehensive Plan for the BIAP 

Projects 

MNC-I did not develop a command-approved master plan that included specific goals, 

objectives, relationships among projects, estimated costs, milestones for completion, and 

organizations accountable for completing and assessing project outcomes for the BIAP projects. 

Rather, the planning was accomplished through a series of documents developed at different 

points in time. These documents include concept papers and accompanying documents related to 

the CERP projects at BIAP, justification documents, BIAP project schedules, project plan 

spreadsheets, informational briefings, and a conceptual master plan. However, these documents 

generally lack a programmatic approach for achieving the overall objective of creating an 

economic zone at the airport. In general, the documents do little more than collectively identify 

the projects that MNC-I planned to undertake and propose a schedule for starting the projects; 

the documents give little or no attention to addressing goals and objectives for economic 

development. 

In written comments on a draft of this report, USF-I stated that MNC-I did develop a master plan 

but noted that it could have been more detailed. As SIGIR stated earlier, we did see a number of 

documents related to the projects at BIAP. However, in SIGIR’s judgment none of these 

documents contained the traditional elements of a project plan, nor did they contain any 

indication that they had been reviewed or approved by MNC-I officials at any level. As such, 

SIGIR did not consider these documents to be plans. 

CERP Guidance Does Not Require Comprehensive Plans for Related Projects 

The MAAWS does not require commanders to develop comprehensive plans for related CERP 

projects. While this may be appropriate for small projects, it becomes more necessary as the size 

and complexity of projects increases. SIGIR believes that this was the case for BIAP. As 

discussed earlier, the CERP projects at BIAP were managed as 46 individual projects rather than 

as an interrelated effort. 

MNC-I has significantly improved its guidance and now requires commanders to address issues 

such as sustainment. Despite these improvements, in SIGIR’s view, the MAAWS guidance still 

needs to address the management needs of larger projects. The content of these plans will vary, 

but issues that might be covered could include capacity building, security, reporting, and a 

strategy to address maintenance and use issues. 

To some degree, the need for plans is identified in a Center for Army Lessons Learned handbook 

on CERP, titled Commander’s Emergency Response Program: Tactics, Techniques, and 

Procedures (March 2008). However, the handbook presents this more as a suggestion than a 

requirement. Nonetheless, the handbook identifies a set of generally accepted principles for 

reconstruction and development programs that guide the development community. Some areas 

identified in the handbook that should require planning include the following: 
28 

• Projects should address capacity building, which involves the transfer of knowledge, 

techniques, and skills to the indigenous people, institutions, and government so that they 

obtain the requisite abilities to deliver essential services to the population. 

• Only projects and services that will have a lasting effect on the local population should be 

selected. Achieving sustainability requires the commander and staff to research and 

analyze all potential projects. 

• Commanders should request, or conduct for themselves, an assessment of local 

conditions before investing financial resources into potential relief and reconstruction 

programs. 

• Enforcing accountability, building transparency into systems, and emplacing effective 

checks and balances to guard against corruption are important components to any relief, 

reconstruction, or development program. Accountability in all actions, including the unit 

CERP, reinforces the legitimacy of the commander and his operations as well as the 

legitimacy of the local government in the eyes of the population. 

The planning documents used to guide the BIAP Economic Zone (BEZ) projects acknowledged 

many of the principles and other development criteria identified in the handbook, but MNC-I’s 

documents did not outline a systematic approach for applying the criteria. Most notably, the 

documents provided insufficient guidance on capacity building and promoting host-country 

ownership. 

In written comments, USF-I agreed that these elements should be included in a plan. However, 

it stated that it was up to the GOI, with the help of U.S. Embassy officials, to do this planning 

rather than MNC-I. SIGIR has previously reported on the importance of ensuring that 

reconstruction projects are consistent with the needs of the host government and that it has the 

capacity to maintain them.11 While MNC-I may not be in position to develop the GOI’s 

capacity, these projects were built with MNC-I’s CERP funding, and thus we believe that MNC-I 

had the responsibility to help ensure that these elements of planning were addressed. 

Project Coordination Was Informal and Not Well Documented 

In written comments on a draft of this report, USF-I stated that MNC-I coordinated the projects 

with GOI representatives and, to a limited extent, with the U.S. Agency for International 

Development (USAID) and the U.S. Embassy. This coordination was accomplished in 

discussions between senior MNC-I and GOI officials. However, coordination with the GOI or 

agreements reached are not documented. Similarly, coordination that may have occurred with 

other U.S. reconstruction agencies is not documented. Discussions with GOI officials disclosed 

 

11 Key Recurring Management Issues Identified in Audits of Iraq Reconstruction Efforts; SIGIR 08-020, Jul. 27, 2008.
29 

that coordination between the GOI and MNC-I was effective in the early stages of the project but 

was not effective in the later stages. 

The MAAWS in use when these projects were undertaken required MNC-I to coordinate CERP 

projects with local GOI agencies, provincial reconstruction teams, USAID, and other 

nongovernmental organizations. However, prior to May 2008, MNC-I was not required to 

document this coordination during the approval process. To determine what coordination 

occurred, we reviewed project files and found that 42 of the 46 project files contained “letters of 

justification,” which are written narratives that outline the purpose and need for proposed CERP 

projects. Of the 42 letters in the project files, 41 stated that the projects had been coordinated 

with GOI agency representatives, 8 letters stated that the projects had been coordinated with 

DoS; 12 none of the letters indicated any coordination with USAID. 

The letters of justification we reviewed contained little detail as to who MNC-I representatives 

spoke with or what agreements may have been reached during coordination with GOI officials. 

Documenting meetings and agreements is important to establishing accountability. Nonetheless, 

a senior U.S. military official told us that MNC-I had extensively coordinated these projects with 

the GOI, to include making presentations to the Council of Ministers and the Deputy Council of 

Ministers. A senior GOI official confirmed that he had frequently met with U.S. military 

officials to discuss the major security and development issues affecting Iraq’s transportation 

infrastructure, including its airports. He stated that as the U.S. began the process of transferring 

responsibility to Iraqi authorities, Iraqi ministries increasingly assumed control, and that process 

was closely monitored by the senior GOI official. There were also periodic reports and 

discussions with Iraq’s National Security Council, chaired by the Prime Minster. A senior GOI 

official further confirmed that the senior MNC-I official was frequently in contact with his office 

and he was regularly briefed on the scope and progress of the initiatives of the projects. The 

senior GOI official also visited the convention center and office building with representatives 

from the ministries of Transportation and Defense and subsequently briefed the Prime Minister, 

who also agreed with the projects. 

At the request of USF-I, we also spoke with another senior GOI official. The senior official 

confirmed that initially MNC-I’s coordination with the GOI was excellent and he was briefed on 

the projects by a senior MNC-I officer once a week. However, when that individual departed, 

the briefings stopped and no further coordination occurred. When asked why the GOI was not 

using some of the projects, the senior official said that there were various reasons that certain 

projects were not used. These include 1) the lack of coordination with MNC-I in the projects’ 

later stages to ensure projects met Iraqi needs; 2) the frequent rotation of the civil affairs 

 

12 The letters of justification generally did not specify whether the projects were coordinated with DoS officials from 

provincial reconstruction teams, the Iraq Reconstruction Management Office, or the Office of the Transportation 

Attaché. 
30 

brigades; 3) the absence of an overall strategic plan for the project; 4) a lack of emphasis by the 

military and the Embassy; and 5) the inability of the GOI to sustain some projects. 

SIGIR also noted during our review that, although the projects were coordinated with the GOI, 

BIAP is not one of the four geographic zones designated as free zones under Iraq’s Free Zone 

Authority Law. As such, the BEZ is not an officially recognized economic zone. 

USAID officials we interviewed recalled that they had been briefed on some of the CERP 

projects at BIAP while they served on the Baghdad provincial reconstruction team. U.S. 

Embassy officials also said they were briefed on the projects, particularly the four main BEZ 

projects. Interestingly, both Embassy and USAID officials told us that they viewed the projects 

as U.S. military efforts and stated that they did not have decision-making authority on how 

CERP funds are spent and which projects would be started. This separation of economic 

development responsibilities between the Department of Defense and civilian agencies further 

illustrates SIGIR’s position that a lack of unity of command was a primary contributor to 

inefficiency, ineffectiveness, and waste in the Iraq reconstruction program. 

In written comments on a draft of this report, USF-I said that MNC-I also collaborated with 

another DoD activity working on economic development. 

Measures to Assess Project Effectiveness Were Not Developed 

MNC-I did not attempt to measure the economic impact of the CERP projects at BIAP or to 

determine whether the projects had a direct impact on the level of violence or economic 

development in Iraq. The MAAWS requires that CERP projects immediately assist the people of 

Iraq; however, the MAAWS did not require performance measures until January 2009. 

The documents MNC-I developed to guide the CERP projects at BIAP identified two goals and 

objectives; however, these were broadly scoped and not easily measured. For example, the goals 

and objectives were to: 

• establish BIAP as an international gateway 

o increase passenger and cargo traffic to Baghdad 

o reestablish Iraq as a member of the international community 

o attract international travelers, businessmen, and investors 

o present a positive impression of reconstruction progress in the country 

• develop a commercial economic zone, known as the BIAP Economic Zone 
31 

o create an economic engine that is a regional revenue generator and employer that 

provides prosperity, stability, and social development for the people of Iraq13

o serve as an economic incubator for the Baghdad area 

o create a secure business environment conducive to sustained economic growth 

o revitalize and modernize facilities benefiting the regional infrastructure 

o attract international participation in the investment of economic revitalization in Iraq 

MNC-I officials said it was not feasible to evaluate the impact of the projects while conducting 

combat operations and other missions in Iraq. MNC-I did track information on the BIAP 

projects, such as the number of projects implemented and the amount of money spent. However, 

MNC-I did not gather information on whether the BIAP projects had any short- or long-term 

effect on the violence or economic development in Iraq. 

The MNC-I official’s statement that evaluating the impact of projects during combat operations 

was not feasible highlights one of SIGIR’s key concerns about the appropriateness of using 

CERP funds for large-scale development efforts. In cases where field commanders use relatively 

small amounts of CERP to better control their areas of operation, it is understandable that impact 

evaluation would take a low priority. However, when CERP projects collectively involve 

$35 million to achieve a goal of improving the economic environment in Iraq, measuring project 

impact seems appropriate. 

In commenting on a draft of this report, USF-I said that a metric indicating project success is that 

the last indirect fire attack on or in the vicinity of the BEZ was May 2007. 

Initial CERP Guidance Inadequate for Large-scale Projects 

In 2005, MNC-I’s initial CERP guidance indicated that most projects averaged $50,000, but by 

the January 2009 iteration, the MAAWS stated, “CERP is intended for projects that can be 

sustained by the local population or government and cost less than $500,000 per project.” While 

the reported project costs increased, the documentation required for project approval remained 

fairly constant until the May 2008 version of the MAAWS, which provided additional criteria for 

high-cost projects. The majority of the CERP projects at BIAP, however, were initiated before 

these improved internal controls went into effect. 

In May 2008, the MAAWS guidance was revised to better address the needs of large-scale 

projects. Among the changes were (1) a requirement for a legal review of all proposed projects; 

(2) documentation of coordination with GOI and provincial reconstruction teams for proposed 

projects costing greater than $50,000, and (3) a requirement that purchasing officers include 

sustainment letters from GOI officials for any construction or equipment project costing $50,000 

 

13 This was labeled as the primary objective of the BEZ initiative. 
32 

or more. In January 2009, the MAAWS guidance was further revised to require performance 

metrics for projects $50,000 or greater, and additional approval for projects costing greater than 

$1 million. 

After the CERP projects at BIAP were initiated, MNC-I designated the 364th Civil Affairs 

Brigade as the National CERP Management Office for Iraq. The brigade reviewed CERP 

proposals from throughout Iraq in an effort to coordinate overall CERP spending. We did not 

conduct an independent review of this process, yet the lessons learned from this effort may be a 

valuable tool for helping commanders decide whether and under what circumstances to use 

CERP funds for large-scale projects. 

Lack of Expertise and Frequent Turnover of Personnel Led to 

Inefficiencies 

The civil affairs brigades that managed the 46 CERP projects at BIAP were under the direct 

supervision of MNC-I headquarters. Multiple civil affairs brigades managed the BIAP projects 

on a rotational basis.14 As a result, the quality of the program management and oversight 

provided was dependent upon the capabilities of the individuals who were in Iraq at the time. At 

times, MNC-I appointed individuals to provide program-level management for the CERP 

projects at BIAP and other U.S. military-funded economic initiatives that were underway. 

MNC-I personnel we interviewed, who provided program oversight in 2007, acknowledged that 

they were not subject-matter experts in engineering or airport development.15 Additionally, they 

stated that they were ambitious and wanted to complete as much as possible during their tours in 

Iraq. After the unit redeployed, they said that they believed that the command emphasis on 

CERP projects at BIAP varied due to command changes in MNC-I and the supporting civil 

affairs brigades. 

In written comments on a draft of this report, USF-I said that the surge of U.S. forces under the 

direct control of MNC-I at the time of this project greatly complicated the command’s on-going 

CERP focus. 

Civil affairs officials told us that they relied primarily on their civilian skills to accomplish the 

tasks at hand because the civil affairs training they received did not address large-scale 

reconstruction efforts. Thus, those who did not have related experience lacked the knowledge 

and expertise necessary to oversee the projects effectively. These deficiencies were exacerbated 

by the fact that the brigades rotated regularly and files were not well-maintained. According to a 

senior USF-I official, the brigade that managed the projects in early 2008 had the expertise to 

 

14 The civil affairs brigades had tours of duty ranging from 6 to 9 months, with an average of 8 months. 

15 The individuals we interviewed were not professional engineers. According to a senior MNC-I military official, 

professional engineers, whom we did not interview, provided oversight for the projects, and MNC-I engaged a GOI 

Ministry of Transportation official for expertise in airport development. 
33 

manage the projects, but acknowledged that after this brigade departed the expertise may have 

been reduced.

The Army has recently recognized that its expeditionary contracting workforce is not adequately 

staffed, trained, or structured and that such conditions constitute a material weakness in its 

operations, and has recently taken steps to address the inexperience of personnel overseeing 

contracts in Iraq, including those for CERP projects. On March 2, 2010, the U.S. Army Vice 

Chief of Staff addressed the lack of trained personnel to assist in the technical monitoring and 

administration of contracts, which are critical to the Army’s success in Iraq. The Vice Chief 

instructed Army commanders to nominate and train contracting officer’s representatives and 

other oversight personnel before deployment to Iraq. This includes identifying and nominating 

contracting officer’s representatives that have experience with the contract activities that they 

will oversee. The Vice Chief also instructed contracting officials to review their representatives’ 

qualifications and training, and to monitor their performance in overseeing contracts. SIGIR is 

hopeful that these lessons learned by the Army will help improve oversight of CERP projects; 

however, SIGIR will continue to monitor oversight of CERP projects in future audits. 

In commenting on a draft of this report, USF-I said that the Vice Chief of Staff’s issue is not the 

same issue discussed in this report. However, SIGIR continues to believe that the discussion is 

relevant to the issues discussed in this report. The contracting officer’s representatives who are 

responsible for overseeing CERP project activities typically come from program office staff. For 

these projects, the various civil affairs brigades were the program office and the ability of their 

personnel to effectively oversee and manage the CERP projects would have been an important 

factor in the projects’ outcome. 

MNC-I Project Data and Documents Were Incomplete and Limited 

Our Analysis 

Project documentation is a recurring problem that SIGIR has identified in many audit reports, 

and these projects similarly had project files that were not well-maintained and project tracking 

data that was incomplete. 

The weaknesses occurred for several reasons, according to USF-I. Primarily, MNC-I 

headquarters officials did not ensure that project information was properly recorded and filed. 

For example, following one transition between brigades, concerns were so great that the 

360th Civil Affairs Brigade placed memoranda in five project files stating that it did not take 

responsibility for the projects it had inherited from its predecessor, the 358th Civil Affairs 

Brigade. 
34 

These long-standing weaknesses in MNC-I’s controls over CERP funds and projects are similar 

to other weaknesses previously reported by SIGIR since 2005.16 For example: 

• MNC-I’s project files were incomplete, which limited our ability to analyze the projects. 

MNC-I requires that CERP project files include a number of documents, similar to a 

contract file, and to use checklists so that military personnel can verify that they have 

included the required documentation in the files. However, during our audit, officials 

were organizing the files, and we received the files on a piecemeal basis. Many of the 

files contained documents on project approval and payments made; however, the files 

lacked key documents related to the transfer of projects to the GOI. 

• The data systems that MNC-I uses to track and record CERP project data are also 

incomplete. MNC-I used two methods to track the CERP projects at BIAP: an MNC-Icreated spreadsheet and the Iraq Reconstruction Management System, which is the 

central database for reporting all projects initiated with CERP. These two methods did 

not track all of the CERP projects at BIAP. For example, MNC-I’s project tracking sheet 

did not include four completed projects with combined costs of about $685,000. 

Similarly, some of the CERP projects were not included in the Iraq Reconstruction 

Management System database, and four projects were entered in the database twice. The 

MAAWS requires accurate reporting of project data to enable MNC-I officials’ 

reconciliation of expenditures on a monthly basis. This data is also used to provide 

project information to the Congress and to justify future CERP funding levels. 

In written comments on a draft of this report, USF-I said that it has made a concerted effort to 

improve its project files and, while there may still be some missing documents, there are not as 

many as in the past. 

 

16 See Appendix A for a list of SIGIR’s previous reports on CERP. 
35 

Conclusions, Recommendations, and Lessons Learned 

Conclusions 

After 4 years of effort and about $35.5 million in expenditures on 46 projects, MNC-I’s goals—

to develop a commercial economic zone at the BIAP that would generate revenue; provide 

prosperity, stability, and social development for the people of Iraq; and establish BIAP as an 

international gateway—have only been partially achieved. SIGIR notes that 22 projects valued 

at $19.3 million had generally successful outcomes. However, 24 projects valued at $16.1 

million have had generally unsuccessful outcomes and these funds are at risk of being wasted 

without further action. SIGIR also notes that in the judgment of senior military officials, the 

BIAP projects were an important part of the overall military surge effort and played a role in 

reducing violence. To USF-I’s credit, it is actively working with the GOI, who now has 

ownership of the facilities that were constructed, to identify opportunities to gain additional 

benefits from the investment that has been made. 

In general, MNC-I officials who managed the CERP projects at BIAP followed the policies and 

procedures that were in place at the time. However, the outcomes of the projects raise questions 

about the overall adequacy of project management, particularly as it relates to the adequacy of 

guidance for implementing CERP projects. SIGIR identified five issues that contributed to the 

management problems for these projects, including: (1) the projects were undertaken without a 

plan to guide the effort and without adequate coordination with U.S. civilian agencies; (2) the 

projects were undertaken without a plan to evaluate the projects’ results and the impact on the 

level of violence in Baghdad; (3) CERP guidance in place at the time included management and 

oversight procedures designed for smaller, quick-reaction projects and did not fully address the 

management needs of large-scale counterinsurgency and economic development efforts; 

(4) MNC-I personnel assigned to the projects lacked expertise in large-scale development 

projects and rotated frequently, which contributed to oversight inefficiencies; and (5) project 

files were not well maintained and project tracking data were incomplete. SIGIR also notes that 

project risk and outcomes were also impacted by (1) the inherent difficulties in undertaking 

projects in a war zone; and (2) difficulties in working with a government that is in the process of 

developing its own form of democracy and processes for governance. 

Over the past several years, DoD and MNC-I have significantly improved their planning and 

management of CERP projects. Guidance improvements and recent changes to address the 

shortages of personnel who are trained as contracting officer’s representative and in meeting 

other CERP-related responsibilities are particularly noteworthy. While these actions address 

some of SIGIR’s concerns about project oversight, gaps still remain with regard to planning. 

CERP guidance does not explicitly require project implementation plans. While this may be 

appropriate for small-scale CERP projects this is not the case for large-scale efforts with multiple 

integrated projects like the BIAP projects. 
36 

Recommendations 

To improve the management of CERP and promote the sustainment of the CERP projects at 

BIAP, SIGIR recommends the following: 

1. The Secretary of Defense should direct the Under Secretary of Defense (Comptroller) to 

revise CERP guidance to include a requirement that a project implementation plan be 

developed for large-scale projects. 

2. The Commanding General, U.S. Forces-Iraq, should enhance ongoing efforts for gaining 

additional benefits from the BIAP project investment by working with GOI officials to 

develop approaches for improving the use and sustainment of CERP-funded BIAP projects 

and to the extent practicable develop a plan for accomplishing any agreed-upon approaches 

for improving the use and sustainment of the projects. 

3. The Commanding General, U.S. Forces-Iraq, should take actions to enhance data systems 

used to track and record CERP-project data. 

Lessons Learned 

Certain of the issues raised by SIGIR in this report have been addressed by DoD during the 

course of the projects’ implementation or were the subject of prior audit recommendations. 

Nonetheless, they provide useful lessons for other contingency operations. 

1. CERP projects were undertaken on a larger scale than anticipated and before the appropriate 

policies and procedures for managing the programs were developed. As a result, program 

implementation problems were experienced. In other contingency situations, such as those in 

Afghanistan, steps should be taken to provide guidance appropriate to the scope of CERP 

projects that will be initiated. 

2. Improved coordination among agencies and host governments, and project performance 

measurement could help U.S. military and development agencies reduce inefficiencies, 

minimize risks, and likely achieve better outcomes. 

3. Inadequate oversight by contracting officer’s representatives and personnel with CERPrelated responsibilities has been a general CERP project management weakness. The 

weaknesses have been caused by a shortage of personnel who have been sufficiently trained 

to perform oversight duties. The U.S. Army Vice Chief of Staff recently reinforced the need 

for leaders and contracting officials to nominate and train personnel prior to deployment. 

4. MNC-I experienced problems in managing CERP files for the BIAP projects. As a result, it 

is difficult to determine accountability for the project outcomes. These problems are 

significant and constitute a major weakness in ensuring that CERP funds are not subject to 

waste and fraud. SIGIR has previously reported on this problem. MNC-I and subsequent 
37 

responsible commands have taken action to improve its processes by noting the importance 

of file management in MAAWS and providing training on MAAWS requirements. 
38 

Management Comments and Audit Response 

USF-I agreed with SIGIR’s recommendation that it take actions to enhance its data systems used 

to track and record CERP-project data. However, it did not agree with SIGIR’s recommendation 

that the Under Secretary of Defense (Comptroller) should revise CERP guidance to include a 

requirement that a project implementation plan be developed for large-scale projects. USF-I also 

disagreed with SIGIR’s assessment on 6 of the 24 projects we identified as having questionable 

outcomes. USF-I has offered to provide support for its position and SIGIR has requested that 

support. USF-I’s comments are in Appendix I. 

According to USF-I’s comments, it is currently working with the Under Secretary of Defense 

(Comptroller) to correct the CERP information in the Iraq Reconstruction Management System 

(IRMS). The objective is to complete the update prior to the shut-down of IRMS on 

September 1, 2010. USF-I will provide IRMS data to users until September 1, 2010 and is 

presently evaluating data tracking mechanisms for after the IRMS shut-down date. 

USF-I did not agree that the Secretary of Defense should revise CERP guidance to include a 

requirement that a project implementation plan be developed for large scale projects. According 

to USF-I this recommendation is no longer applicable because there are no CERP funded largescale projects. Thus, USF-I believes that the recommendation is dated. 

SIGIR continues to believe its recommendation has merit because, while the approval 

requirements for CERP projects have been strengthened, it is still possible to execute projects 

over $1 million if approved by the Secretary of Defense. Also, to the extent that DoD is 

involved in stabilization and reconstruction operations in Iraq and in other theaters, the 

possibility that other large-scale projects may be undertaken remains. Lastly, it is also possible 

to initiate multiple related projects that could have a combined value in the millions of dollars, as 

happened with the BIAP projects. Effectively planning for these types of projects will remain a 

requirement that should be addressed in DoD guidance. Consequently, this recommendation will 

remain open. 

USF-I stated that 6 of the 24 projects SIGIR identified as not being used were actually being 

used. These were the: 

• Cargo Terminal Refurbishment 

• Iraq Aviation Institute Rehabilitation 

• Iraq Aviation Institute Automation Contract 

• Iraq Aviation Institute Furniture Purchase 

• Iraq Aviation Institute Facility Improvement 
39 

• Iraq Aviation Institute Water Supply Pipe 

USF-I also partially concurred with our assessment of the Iraq Aviation Institute access road and 

parking lot, and business center renovation. 

USF-I has offered to provide support for its position, and SIGIR has requested that support. 

SIGIR notes that its assessment represents the point in time when our field visit was made 

(September 2009) and that we reported that USF-I was actively working with the GOI to 

improve facility utilization. An increased use of the facilities as a result of continuing 

engagement with the GOI would support SIGIR’s position that such actions could help ensure 

that the U.S. investment at BIAP realizes the maximum benefit. 

USF-I also provided a number of technical comments that SIGIR addressed as appropriate in the 

report. See Appendix I for a copy of the USF-I comments and SIGIRs response to each point.. 
40 

Appendix A—Scope and Methodology 

Scope and Methodology 

In June 2009, the Special Inspector General for Iraq Reconstruction (SIGIR) announced Project 

9026 to examine the use of Commander’s Emergency Response Program (CERP) funds at the 

Baghdad International Airport (BIAP). Our reporting objective for the CERP-funded BIAP 

projects were to examine their (1) cost and outcome and (2) management. SIGIR performed the 

audit under the authority of Public Law 108-106, as amended, which also incorporates the duties 

and responsibilities of inspectors general under the Inspector General Act of 1978. SIGIR 

conducted its work during June 2009 through March 2010 in Baghdad, Iraq. 

To determine project costs and outcomes, we analyzed disbursement data from the Standard 

Finance System (Army) and the U.S. Army Corps of Engineers’ Financial Management System 

and additional cost and project schedule data from documents in the CERP project files, such as 

project cost estimates, initial purchase request forms, contracts, statements of work, bills of 

quantities, notices to proceed, invoices, receiving reports, and payment documents. We also 

conducted two site visits. On September 28 and 29, 2009, we visited most of the project sites, 

and on November 16, 2009, we conducted a follow-up site visit to observe the Business Center 

Security Building and the Transportation Operations Compound. The projects we visited 

encompassed 38 of the individual CERP projects and about $29 million spent at BIAP. During 

site visits, we interviewed Government of Iraq (GOI) officials who happened to be at the project 

sites during our visit. 

As a result of our analysis, we grouped the projects into two categories: those that were generally 

successful and those that had questionable outcomes. Overall, the generally successful projects 

are being used as intended. They have been completed, transferred to the GOI, and mostly 

sustained by the GOI. We also included one-time service contracts in the generally successful 

category where appropriate. In contrast, we questioned the value of projects that are not 

currently being used by the GOI, have not been maintained, are being used minimally or not as 

intended, or were terminated before completion. We also questioned the outcomes of projects 

where the project files contained minimal evidence of work performed. Where applicable, we 

took into account the results of third-party assessments that were related to the projects; we did 

not conduct independent engineering assessments to verify the third parties’ results. Not all of 

the project files were complete, so we accepted testimonial evidence regarding project 

completion, transfer, and sustainment for some projects. When the preponderance of the 

available evidence suggested that project outcomes were favorable, we categorized the projects 

as generally successful. In light of these limitations, we believe our categorizations are 

reasonable given the data we reviewed. 
41 

To evaluate the management and oversight of the CERP projects at BIAP, we analyzed 

documents from the CERP project files, such as the projects’ justification letters, legal approval 

documents, funding approval documents, and evidence of materials and services received 

compared to payments made. We also interviewed officials from the 364th Civil Affairs Brigade, 

U.S. Army Corps of Engineers, Gulf Region Division (including its Central district office), as 

well as current and former Multi-National Force-Iraq and Multi-National Corps-Iraq (MNC-I) 

officials who provided project oversight. These units are now part of or attached to U.S. ForcesIraq. Because multiple CERP operating procedures were in effect during the time periods in 

which the projects were awarded, we did not attempt to conduct an in-depth file review to 

determine whether all of the criteria had been followed. Instead, we limited our review to those 

areas that might suggest material internal control weaknesses. 

Our review of the management and oversight of the projects included a review of the 

coordination of the CERP projects. To do this, we interviewed officials from the Department of 

State (including the Office of the Transportation Attaché, Economic Affairs, and the Iraq 

Transition Assistance Office), the United States Agency for International Development, the U.S. 

Army Corps of Engineers Gulf Region Division (including its Central district office), the 

364th Civil Affairs Brigade, and current and former MNC-I and Multi-National Force-Iraq 

officials who were involved with the projects. We also reviewed evidence of coordination in the 

project files. The files contained minimal evidence of coordination with the GOI; but a senior 

GOI official stated that the projects had been collaborated with the GOI. 

Additionally, our review of the management and oversight of the projects included efforts taken 

to transition the completed projects to the GOI and the GOI’s efforts to sustain the projects. To 

do this, we analyzed letters or other evidence—including testimonial evidence—that the projects 

had been transferred to the GOI. To evaluate whether a project appeared to have been 

appropriately sustained and used for its intended purpose, we primarily relied on observations 

and testimonial evidence gathered during our site visit in September 2009. We also considered 

the results of after-action reports completed by MNC-I officials, an airport certification 

assessment completed by the U.S. Federal Aviation Administration in March 2009, other 

documentation gathered over the course of the audit, and testimonial evidence of senior GOI 

officials. 

We conducted this audit in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 
42 

Use of Computer-processed Data 

To achieve the assignment’s objectives, we relied on computer-processed data contained in the 

Army Standard Finance System, and to a lesser extent we also relied on data in the U.S. Army 

Corps of Engineers’ Financial Management System. We did not assess either system’s financial 

controls, but we assessed the reliability of the financial systems’ output through comparison to 

available documentation in the project files. Based on these assessments and tests, we concluded 

that the data were sufficiently reliable to be used in meeting the assignment’s objectives.

Internal Controls 

In conducting the audit, we assessed certain internal controls pertinent to the audit objectives 

with respect to the CERP. Specifically, we identified and assessed internal or management 

controls including: 

• procedures for awarding and tracking CERP projects after award 

• procedures for monitoring and evaluating activities in the field 

• controls related to the contract award, contract oversight, and award-fee decisions 

Prior Coverage 

We reviewed reports by SIGIR, the Government Accountability Office, and the U.S. Army Audit 

Agency. 

Special Inspector General for Iraq Reconstruction 

Commander’s Emergency Response Program: Hotel Construction Completed, but Project 

Management Issues Remain, SIGIR 09-026, 7/26/2009. 

Commander’s Emergency Response Program: Muhalla 312 Electrical Distribution Project 

Largely Successful, SIGIR 09-025, 7/26/2009. 

Commander’s Emergency Response Program in Iraq Funds Many Large-scale Projects, 

SIGIR 08-006, 1/25/2008. 

Management of the Commander’s Emergency Response Program in Iraq for Fiscal Year 2006, 

SIGIR 07-006, 4/26/2007. 

Management of the Commander’s Emergency Response Program for Fiscal Year 2005, 

SIGIR 05-025, 1/23/2006. 

Management of Commanders’ Emergency Response Program for Fiscal Year 2004, 

SIGIR 05-014, 10/13/2005. 
43 

Government Accountability Office 

Actions Needed to Improve Oversight and Interagency Coordination for the Commander’s 

Emergency Response Program in Afghanistan, GAO-09-615, 5/18/2009. 

Military Operations: Actions Needed to Better Guide Project Selection for Commander's 

Emergency Response Program and Improve Oversight in Iraq, GAO-08-736R, 6/23/2008. 

U.S. Army Audit Agency 

Commander’s Emergency Response Program Multi-National Division – North, Audit Report: 

A-2009-0169-ALL, 7/28/2009. 
44 

Appendix B—Summary of 46 CERP Projects at BIAP 

This appendix summarizes the costs and outcomes of the 46 CERP projects at BIAP. To 

determine project costs and outcomes, we analyzed disbursement data from the Standard Finance 

System (Army) and the U.S. Army Corps of Engineers’ Financial Management System and 

additional cost and project schedule data from documents in the CERP project files, such as 

project cost estimates, initial purchase request forms, contracts, statements of work, bills of 

quantities, notices to proceed, invoices, receiving reports, and payment documents. We also 

conducted two site visits. On September 28 and 29, 2009, we visited most of the project sites, 

and on November 16, 2009, we conducted a follow-up site visit to the Business Center Security 

Building and the Transportation Operations Compound. The projects we visited encompassed 

38 of the individual CERP projects and about $29 million spent at BIAP. During site visits, we 

interviewed GOI officials who happened to be at the project sites during our visit. 

To present our analysis, we grouped the projects into two categories: those that were generally 

successful and those that had questionable outcomes. Overall, the generally successful projects 

are being used as intended. They have been completed, transferred to the GOI, and mostly 

sustained by the GOI. We also included one-time service contracts in the generally successful 

category where appropriate. The questionable outcome projects include projects that are not 

being used by the GOI, have not been maintained, are being used minimally or not as intended, 

or were terminated before completion. We also questioned the outcomes of projects where the 

project files contained minimal evidence of work performed. Where applicable, we took into 

account the results of third-party assessments that were related to the projects; we did not 

conduct independent engineering assessments to verify the third parties’ assessments. Not all of 

the project files were complete, so we had to rely on testimonial evidence regarding project 

completion, transfer, and sustainment for some projects. When the preponderance of the 

available evidence suggested that project outcomes were favorable, we categorized the projects 

as generally successful. In light of these limitations, we believe our categorizations are 

reasonable given the available evidence. 

The projects with generally successful outcomes are discussed first, in descending order of cost; 

the projects with questionable outcomes are discussed later, also in descending cost order. 

Generally Successful Outcomes 

There were 22 generally successful projects that cost $19,307,850, or about 54% of total CERP 

costs at BIAP. 
45 

Office Tower 

Reported 

Cost: 

$4,238,552 

Outcome: Renovation Completed, Transferred, and Mostly Sustained 

Discussion: The office tower was initiated in April 2007, completed on June 30, 2008, and 

was transferred to the GOI on January 20, 2010, nearly 19 months after the 

project was completed. A private company has been operating the office tower 

for the GOI since October 2008. The management contract does not involve 

CERP funds, but MNC-I negotiated the management contract between the 

private company and the GOI because the management contract promotes project 

sustainment by providing the GOI a revenue stream and helping to ensure that 

the facility is used as intended. The initial U.S. investment has resulted in some 

private investment and enhanced professional opportunities for people in Iraq; 

however, the venture has not yet generated a profit. 

Caravan Hotel 

Reported 

Cost: 

$4,164,588 

Outcome: Construction Completed, Transferred, and Mostly Sustained 

Discussion: The Caravan Hotel was formally transferred to the GOI in August 2009. Almost 

half of the rooms are rented to permanent customers. The hotel’s occupancy has 

increased steadily since it was first opened for business in November 2008, and 

as of November 2009, the monthly occupancy was about 70%. Since the transfer 

date, the GOI has continued to honor the management contract that is in place, 

which includes profit sharing between the company that manages the hotel and 

the GOI. The current 2-year management contract expires in August 2010; it 

contains an option for the GOI to extend the contract into a third year. 

Drinking Water System 

Reported 

Cost: 

$1,731,050 

Outcome: Utility Repair Completed, Transferred, and Mostly Sustained 

Discussion: Initiated in August 2007, the drinking water system project was to repair and 
46 

increase the capacity of the drinking water system at BIAP to ensure a safe, 

reliable drinking water source. This project was completed in December 2007. 

Although we did not evaluate the condition of the system, MNC-I officials 

assessed the system on September 1, 2009, and found it to be in good working 

condition. 

Air Traffic Controller Replacement 

Reported 

Cost: 

$1,655,667 

Outcome: One-time Service Completed 

Discussion: As the air traffic to BIAP increased in 2007, the GOI faced a chronic shortage of 

certified air traffic controllers to accommodate the increased civil air traffic at 

BIAP. Therefore, MNC-I initiated the air traffic controller replacement project 

in August 2007 to provide four temporary civilian air traffic controllers for the 

BIAP control tower to replace Iraqi controllers while they received advanced 

training to manage the increased workload. 

Upon initial review, we questioned whether CERP funds could be used to pay for 

the salaries of contractors who served as temporary replacements for GOI air 

traffic controllers and whether a sole-source acquisition was needed in this case. 

Upon further review, we determined that although the funds were used to pay the 

salaries of air traffic controllers while ICAA air traffic controllers attended 

training, the funds were used to pay those salaries indirectly through a corporate 

contractor; therefore, the use of the funds was not prohibited by laws and 

regulations governing CERP. Also, the justification documents for the award 

sufficiently explained the urgent requirement that necessitated limiting 

competition; the contracted air traffic controllers reported to work in November 

2007 to meet this need. 

Electrical Generators 

Reported 

Cost: 

$1,457,641 

Outcome: Equipment Repair Completed, Transferred, and Mostly Sustained 

Discussion: This project was initiated in June 2007. When we visited the project site in 

September 2009, 13 of 14 electrical generators, which are used to provide backup 
47 

electricity for BIAP, were operational. However, because electricity at BIAP is 

unreliable, the generators are used more frequently than intended. During our 

visit, we observed that the fuel tanks that supplied the generators appeared to be 

full. 

Trash Equipment 

Reported 

Cost: 

$1,430,757 

Outcome: Equipment Purchase and Construction Completed, Transferred, and Mostly 

Sustained 

Discussion: This project was initiated in April 2007. It included the purchase of trash 

equipment and construction of a trash transfer station. The trash equipment was 

purchased and appeared to have been used regularly; thus, we categorized this 

project as generally successful. The trash transfer station, however, appeared not 

to have been used for its intended purpose, which was to serve as a collection 

point for the incinerators. When we visited the transfer station in September 

2009, we observed smoke stains on the cement bins, which appeared to have 

been caused by trash being burned in the bins. According to MNC-I officials, 

burning trash in this manner is a standard practice throughout Iraq. 

Loop Mural 

Reported 

Cost: 

$900,000 

Outcome: One-time Service Completed, Transferred, and Mostly Sustained 

Discussion: Initiated in August 2007, this project commissioned Iraqi artists to paint a mural 

on the wall that borders the access road to BIAP. The mural was intended to 

reflect, in a progressive nature, historical and economic development themes. 

The concept was to provide patrons driving along the access road with scenes 

that represent the transition of the Iraqi economy and to offer a perspective of 

future economic development. 

We viewed the mural from vehicles during our site visit in September 2009. 

Although MNC-I officials stated that the mural served its intended purpose, it is 

unclear from MNC-I project files whether the mural had any impact on Iraqis 

travelling to and from BIAP. 
48 

Sewage System 

Reported 

Cost: 

$836,350 

Outcome: Utility Renovation Completed and Transferred 

Discussion: Initiated in August 2007, this project was a partial renovation of the sewage 

system at BIAP. We reviewed the file for this project and found that operations 

and maintenance were terminated from the contract because the ICAA had a 

maintenance staff capable of operating and maintaining the sewer system and the 

related sewage pumping machinery. MNC-I civil affairs personnel assessed the 

sewage system on September 1, 2009, and found the facility to be minimally 

maintained but fully functional. We did not conduct an engineering assessment 

to verify MNC-I’s results, but we visited the project site in September 2009 and 

confirmed that the system appeared to be operational. While the evidence 

suggests that the project has generally not been sustained, we include it in the 

generally successful category because it currently serves its intended purpose and 

the GOI has performed some maintenance. 

Transportation Operations Compound 

Reported 

Cost: 

$487,590 

Outcome: Renovation Completed, Transferred, and Mostly Sustained 

Discussion: This project was initiated in February 2008. When we arranged our original site 

visit in September 2009, visiting the transportation operations compound was not 

on the itinerary. We later reviewed the project file and found evidence that 

CERP funds had been spent on the facility. We visited the project site in 

November 2009 and observed that the renovation of the transportation operations 

compound maintenance bays, washing racks, office space, and parking areas, 

which were included in the project, appeared to have been used as intended. For 

example, during our visit, an Iraqi worker was cleaning a bus in the wash bay. 
49 

Health Clinic Equipment 

Reported 

Cost: 

$363,574 

Outcome: Equipment Purchase Completed, Transferred, and Mostly Sustained 

Discussion: This project was initiated in June 2007. It included the purchase of equipment 

and furniture and the completion of other repairs. When we visited the clinic in 

September 2009, many patients were at the clinic, and the equipment and facility 

appeared to be used as intended. 

Trash Clean-Up 

Reported 

Cost: 

$350,000 

Outcome: One-time Service Contract, Service Provided 

Discussion: This project was initiated in October 2006 to clean up trash around the four main 

BIAP Economic Zone (BEZ) facilities. This was a one-time project to remove 

debris created by Coalition Forces during combat and later operations in the 

BIAP area. The project appeared to have served its intended purpose; during our 

site visits in September and November 2009, the area where the four main BEZ 

projects are located appeared to be free of battle debris. 

Storm Water Drainage System 

Reported 

Cost: 

$345,000 

Outcome: Utility Renovation Completed, Transferred, and Mostly Sustained 

Discussion: This project, initiated in May 2007, was to renovate two storm water drainage 

pump stations, which drain water from the airport to protect the runway’s 

foundation and underground utilities. The water table around BIAP is high, and 

if it is not drained properly, water could flood the utility tunnels and potentially 

cause significant damage to the runway. MNC-I officials conducted extensive 

follow-up visits on this project and found that the water was being drained but 

that the equipment had not been maintained to standards. 

MNC-I officials addressed the problems with the equipment by teaching GOI 
50 

officials how to operate, repair, and maintain the equipment. MNC-I civil affairs 

personnel conducted follow-up assessments and found that most necessary 

repairs had been completed and that both pump stations were in full operation 

when MNC-I visited in July 2009. When we visited the project site in September 

2009, we noted that the fuel tanks to power the pumps were empty; however, fuel 

was in the pumps and the water appeared to have been drained as intended. 

T-Wall Mural 

Reported 

Cost: 

$280,000 

Outcome: One-time Service Provided 

Discussion: This project was initiated in May 2007. Similar to the loop wall mural, the 

purpose of the T-wall mural was to beautify BIAP and to reflect hope. Unlike 

the loop wall mural, the T-wall mural was painted on a temporary blast wall, 

only remnants of which are still on site at BIAP. It is unclear whether these 

murals had any impact on potential investors travelling to and from BIAP; 

however, the project was intended to be a temporary art installation and, as such, 

it appears to have been used as intended. 

Engineering Study for BIAP Sewer, Water, Electric, and Storm 

Water 

Reported 

Cost: 

$252,000 

Outcome: One-time Service Provided 

Discussion: Initiated in July 2007, this project was used to hire an engineering company to 

locate, assess, and record the capabilities of the utilities’ infrastructure at BIAP. 

MNC-I considered the report’s recommendations when planning the electricity, 

water, sewer, and storm water projects. However, MNC-I did not implement all 

of the recommendations. We did not conduct an independent engineering 

evaluation to determine the impact of MNC-I’s failure to implement some of the 

recommendations raised in the assessment reports. 
51 

Business Center Management Contract II 

Reported 

Cost: 

$211,200 

Outcome: One-time Service Provided 

Discussion: For this project, initiated in December 2007, an Iraqi company was hired to 

operate, manage, and maintain the business center. According to MNC-I 

officials, the business center was used as intended until the facility was 

transferred to the GOI, which occurred after the management contract expired. 

Convenience Store and Coffee Shop 

Reported 

Cost: 

$179,000 

Outcome: Renovation Completed, Transferred, and Mostly Sustained 

Discussion: The convenience store and coffee shop project was initiated in August 2007 and 

was ultimately opened as a restaurant. The restaurant had previously been 

opened under the name “Teddy D’s,” and it functioned for a while after it was 

transferred to the GOI. After transition, while under GOI control, the equipment 

purchased with CERP funds was removed and the business was closed. Due to 

the lack of detail in the contractor’s invoices, we were unable to determine the 

cost of the equipment. 

During 2009, a public auction was held to allow private investors to bid on the 

space. The company that won the contract provided new equipment and 

furniture, built a screened-in back deck, added a building, made other 

improvements to the interior and landscaping, and reopened the facility as a 

restaurant under the name “Lido.” We observed that the restaurant was open for 

business during our site visits. Thus, while we acknowledge that some of the 

funds spent on the original equipment that was removed from the facility 

constitute waste, the overall project has been sustained by the GOI and generally 

is being used as intended. 
52 

Health Clinic Renovation 

Reported 

Cost: 

$160,500 

Outcome: Renovation Completed, Transferred, and Mostly Sustained 

Discussion: This project was initiated in November 2006 to renovate the health clinic facility 

at BIAP. When we visited the clinic in September 2009, we observed many 

patients at the clinic, and the equipment and facility appeared to be used as 

intended. 

Business Center Management Contract I 

Reported 

Cost: 

$142,840 

Outcome: One-time Service Provided 

Discussion: Initiated in December 2006, this project hired an Iraqi company to operate, 

manage, and maintain the business center. According to MNC-I officials, the 

business center was used as intended until the facility was transferred to the GOI, 

which occurred after the management contract expired. The project was 

continued for another year, and the contract was awarded to the same Iraqi 

contractor as the first management contract. 

Uninterruptible Power Supply at Air Traffic Control Tower 

Reported 

Cost: 

$47,547 

Outcome: Equipment Purchase Completed, Transferred, and Mostly Sustained 

Discussion: This project was initiated in December 2006 to purchase equipment to renovate 

the uninterruptible power supply system at the BIAP air traffic control tower. 

When we visited the project site in September 2009, we observed that the system 

was completed and is operational; however, Iraqi officials expressed concern that 

it is relied on too frequently. They explained that when electrical grid power is 

not available, the uninterruptible power supply system activates, which gives 

them time to turn on the back-up generator. Various batteries were purchased 

with U.S. funds but have lost their charge—due to extensive use—and need to be 

replaced because they are not rechargeable. 
53 

Business Center Security Check Point 

Reported 

Cost: 

$42,594 

Outcome: Construction Completed, Transferred, and Mostly Sustained 

Discussion: Initiated in July 2006, this project funded the construction of a guard shack and 

the installation of a security fence outside of the business center facility. When 

we visited the project site in September 2009, the fence was intact and guards 

continued to use the shack at the checkpoint while on duty. 

Fire System Test 

Reported 

Cost: 

$23,800 

Outcome: One-time Service Provided 

Discussion: This project was initiated in April 2007 and resulted in an assessment of the fire 

system at BIAP’s main terminals. The project led to a proposed U.S. 

government project that was never funded. However, in the summer of 2009, 

MNC-I officials met with representatives from the Ministry of Transportation 

and the Iraq Civil Aviation Authority (ICAA) to discuss potential GOI funding 

for the project. The GOI has put the project out for bid, but a contract to improve 

the fire system has not yet been awarded. 

Airport Signs 

Reported 

Cost: 

$7,600 

Outcome: Equipment Purchased, Transferred, and Mostly Sustained 

Discussion: The intent of this project was to design and install three signs that read “Baghdad 

International Airport” in Arabic and one sign that read “Baghdad” in English. 

MNC-I officials confirmed that the signs were purchased and installed at BIAP. 

We did not verify the outcome or sustainment status of this project because we 

did not locate the signs during our site visits. 
54 

Generally Unsuccessful Outcomes 

There were 24 projects with questionable outcomes that cost $16,147,020, or about 46% of total 

CERP costs at BIAP. USF-I disagreed with our assessment of 6 of the 24 projects we identified 

as having questionable outcomes. USF-I has offered to provide support for its position and 

SIGIR has requested that support. 

Convention Center 

Reported 

Cost: 

$5,725,380 

Outcome: Renovation Partially Completed, Contracts Terminated 

Discussion: The CERP funds spent on the convention center are at risk of being wasted. The 

project was initiated in January 2007 with the purpose of renovating two old 

terminal buildings for use as convention center halls at BIAP. The project 

consisted of two contracts, both of which GRD awarded on behalf of MNC-I and 

both of which were terminated. 

When we visited the project site on September 28, 2009, we observed that both 

buildings required significant finish work. Nevertheless, two events were held in 

Hall 1 of the convention center in late 2008, and a third was held in December 

2009. MNC-I officials estimated that one of these events, a 3-day oil exposition 

held in December 2008, generated about $1 million in revenue. Potential 

investors have repeatedly expressed interest in holding events at the convention 

center. USF-I officials told us that they did not plan to spend additional funds on 

the convention center and transferred it to the GOI “as is” on January 20, 2010. 

Incinerators 

Reported 

Cost: 

$2,939,896 

Outcome: Equipment Purchase Completed, Not Being Used 

Discussion: The project was initiated in June 2007 to install incinerators at BIAP. Two 

incinerators were purchased and installed, and the project was transferred to the 

GOI in May of 2008. On September 28, 2009, we observed that the fuel tank 

was empty and confirmed that the incinerators appeared not to have been used 

recently. SIGIR asked a senior GOI official why the incinerator was not used, 

and he stated that Iraqis do not use incinerators, raising questions about project 
55 

coordination with the GOI. Because the incinerators are not used, SIGIR 

considers the $3 million spent on the incinerators as wasted. 

Cargo Terminal Refurbishment 

Reported 

Cost: 

$1,958,792 

Outcome: Renovation Completed, Used Minimally, Not Maintained 

Discussion: This project was initiated during August 2007. During our site visit in 

September 2009, we observed that the cargo terminal was in a state of disrepair 

and had garbage strewn about. Some of the equipment purchased with U.S. 

funds seemed never to have been used or appeared damaged. For example, one 

of the generators and one of the forklifts were still wrapped in their original 

plastic covering. Also, the large metal doors of the cargo terminal, which had 

been repaired as part of this project, were damaged to the point that they were 

nonoperational. 

USF-I did not agree with SIGIR’s assessment and said that the cargo terminal is 

being actively used. SIGIR notes that its assessment reflects conditions at the 

time of our visit. 

Air Traffic Controller Training Center 

Reported 

Cost: 

$1,788,045 

Outcome: Construction Completed, Used Minimally 

Discussion: This project was initiated in August 2007. In September 2009, we visited the air 

traffic controller training center, which was not being used at that time to train air 

traffic controllers. Officials on site confirmed that the CERP-funded project was 

limited to the building’s construction; the project did not include furniture or 

training equipment. The GOI has not purchased equipment, such as a flight 

simulator, for the training center because GOI officials expected the U.S. 

government to purchase the equipment. Instead, students use a mock trainer that is 

made of plywood and uses toy airplanes. Most of the air traffic controller training 

takes place at the BIAP air traffic control tower, not the CERP-funded facility. 
56 

Iraq Aviation Institute Access Road and Parking Lot 

Reported 

Cost: 

$1,041,648 

Outcome: Construction Completed, Used Minimally 

Discussion: Initiated in April 2007, this project was to construct an access road and a 100-car 

parking lot for the Iraqi Aviation Institute. The parking lot serves both the Iraq 

Aviation Institute and the air traffic controller training center, which are adjacent 

to one another. However, because both facilities are used minimally, the parking 

lot is used minimally. USF-I partially concurred with SIGIR’s assessment of this 

project. In its written comments, USF-I said that the driveway and parking lot in 

question currently are in a controlled area. As a result, most aviation students 

use government-provided transportation. USF-I projects that the need for the 

parking lot will dramatically increase as the stability in Iraq improves and 

becomes open to the public. 

Cargo Terminal Automated Inventory System and Management 

Contract 

Reported 

Cost: 

$459,996 

Outcome: System Purchased but License Agreement Not Signed, Management Contract 

Terminated 

Discussion: The cargo terminal automated inventory system project was initiated in August 

2007 and was awarded concurrently with the initial cargo center renovation 

contract. The automated inventory system project, which included a 

management contract to run the system, was descoped. The reason cited was that 

representatives from the Iraqi Airways cargo terminal facility refused to sign 

license agreements with cargo inventory software companies. U.S. funds were 

used to purchase 25 personal computers for the system; however, the inventory 

system currently used at the cargo terminal is not automated. Consequently, the 

CERP funds spent on this project were wasted. 
57 

Cargo Terminal Additional Equipment 

Reported 

Cost: 

$400,965 

Outcome: Equipment Purchase Completed, Not Maintained 

Discussion: The cargo terminal additional equipment project was approved in February 2008. 

The project provided additional equipment that was not included in the original 

contract, such as high-loaders, a potable water station, and a fan for the 

ventilation system, to continue the effort to bring the facility up to international 

standards. We visited the facility in September 2009, and it was in a state of 

disrepair. The additional funds spent on this project were not coordinated as part 

of an overall effort to bring the facility to international standards, which suggests 

the funds could have been put to better use. 

Iraq Aviation Institute Rehabilitation 

Reported 

Cost: 

$398,502 

Outcome: Renovation Completed, Used Minimally 

Discussion: Initiated in October 2006, this project repaired battle damage to a former 

vocational-technical school, which became the Iraq Aviation Institute. During 

the contract bidding stage, MNC-I noted that the building had not been used for 

many years but was still structurally sound. When we visited the Institute in 

September 2009, it appeared to have been used minimally. 

USF-I did not agree with SIGIR’s assessment and said in its written comments 

that the institute is fully staffed and operational. SIGIR notes that its assessment 

reflects conditions at the time of our visit. 

Iraq Aviation Institute Automation Contract 

Reported 

Cost: 

$186,493 

Outcome: Equipment Purchase Completed, Used Minimally 

Discussion: Initiated in April 2007, this project was to provide automation equipment, which 

included a server to provide Internet access for the Aviation Institute. When we 
58 

visited the project site in September 2009, we noted that multiple computers were 

in various offices, classrooms, and laboratories throughout the building, but on 

the day of our visit, they were not being used by students during instructional 

sessions. Also, they appeared to have been used minimally. 

USF-I did not agree with SIGIR’s assessment and said in its written comments 

that the institute is fully staffed and operational. SIGIR notes that its assessment 

reflects conditions at the time of our visit. 

Runway Scrape and Paint 

Reported 

Cost: 

$177,870 

Outcome: Service Partially Provided, Project Terminated 

Discussion: The scrape and paint project was initiated in January 2008 due to rubber buildup 

and improper marking on the civilian runway, which were safety hazards for 

landing aircraft. The original contractor completed the scraping portion of the 

project, but ICAA-imposed delays and other restrictions prevented the contractor 

from painting the runway immediately after scraping. During this time, flight 

patterns changed, and the portion that had been scraped had more traffic than 

usual. MNC-I considered hiring another contractor to finish the painting portion 

of the project, but the U.S. Air Force determined that the runway should be 

scraped again before painting due to excessive rubber buildup. The Air Force 

also recommended that MNC-I re-bid the contract. MNC-I officials received a 

few bids that exceeded the amount remaining on the project’s obligation. MNC-I 

officials terminated this project on September 2, 2009, and the funds used to 

originally clean up the runway are at risk of being wasted. 

When we visited BIAP in November 2009, we observed that excessive rubber 

buildup on the takeoff and landing strip continues to obscure runway markings. 

However, Iraqi officials showed us a scraping machine they had purchased with 

GOI funds to remove the rubber. At the time of our visit, the ICAA had just 

received the equipment and planned to send GOI officials to training to learn 

how to operate the equipment. 
59 

Business Center Building Renovation 

Reported 

Cost: 

$168,550 

Outcome: Renovation Completed, Not Being Used 

Discussion: Initiated in November 2006, this project renovated an old Ba’athist airport 

terminal to be used as a business center. The business center was the first of the 

four main BIAP Economic Zone projects. When we visited the project site in 

September 2009, the doors were padlocked. A GOI official escorted us through 

the building; it appeared to have been renovated, but it was vacant and 

abandoned. In its written comments on a draft of this report, USF-I stated that 

the building was turned over to the GOI in fully satisfactory condition, and that 

the current state of the building is the result of the GOI’s inability to properly 

maintain the structure. 

Air Traffic Control Standby Generator 

Reported 

Cost: 

$128,000 

Outcome: Equipment Repair Completed, Not Maintained 

Discussion: This project was initiated by the U.S. Army Corps of Engineers in September 

2005 to repair the electrical-mechanical and exhaust systems to make the 

generator functional. The GOI did not conduct necessary on-going maintenance, 

and as a result, the generator is not working. U.S. Army Corps of Engineers 

officials were not involved with the project after it was transferred to the GOI, 

thus they did not know why the GOI did not conduct ongoing maintenance. At 

the time SIGIR visited the generator project site, it was unclear which generator 

was repaired using CERP funds. MNC-I, U.S. Army Corps of Engineers, and 

GOI officials later confirmed that CERP funds were used to repair the large 

generator, which is located to the left of the main entrance of the tower. The 

project was completed in August 2007. The repaired generator had a one-year 

warranty, which expired in August 2008. GOI officials on site showed how they 

had connected a newer, smaller generator to the large generator, which enables 

them to power the control tower when power is not available from the electrical 

grid. 
60 

Iraq Aviation Institute Furniture Purchase 

Reported 

Cost: 

$112,138 

Outcome: Equipment Purchase Completed, Used Minimally 

Discussion: Initiated in April 2007, this project was to provide furniture for the Iraq Aviation 

Institute. When we visited the project site in September 2009, we noted that the 

various offices, classrooms, and laboratories were furnished throughout the 

building, but on the day of our visit, the furniture was not being used by students 

during instructional sessions. According to GOI officials, the building is used to 

provide training on an as-needed basis. 

USF-I did not agree with SIGIR’s assessment and said in its written comments 

that the institute is fully staffed and operational. SIGIR notes that its assessment 

reflects conditions at the time of our visit. 

Engineer Retainer Contract II 

Reported 

Cost: 

$98,000 

Outcome: Minimal Evidence of Work Performed 

Discussion: MNC-I officials did not know the results of the work performed by Iraqi 

engineers hired on retainer contracts to assist contracting officers’ representatives 

with daily quality assurance and other quality checks. The engineers provided 

these services on projects such as the Caravan Hotel, which were executed by 

civil affairs brigades rather than GRD. MNC-I civil affairs personnel could not 

find evidence in the project files to verify whether the engineers had completed 

daily reports or had provided other feedback. The officials said that if the 

engineers had produced daily reports, the documentation would have been 

voluminous; thus, previous brigades may not have maintained the reports in the 

CERP project files after the projects were completed. Due to a lack of 

documented oversight, the funds spent on this project constitute potential waste. 
61 

Culvert Lids 

Reported 

Cost: 

$90,000 

Outcome: Minimal Evidence of Work Performed 

Discussion: This project was initiated in February 2005 to recast 550 concrete culvert lids. A 

GOI official verified that there was a CERP project related to the culvert lids; 

however, the official could not remember the location of the lids. An assessment 

conducted by the U.S. Federal Aviation Administration in late February 2009 

found numerous open vaults in the taxiway strips at BIAP; additionally, large 

concrete vault lids were on site but were no longer being used. We did not 

attempt to verify whether lids identified in the Federal Aviation Administration 

report were the culvert lids that were purchased with CERP funds because we did 

not receive the project file until after we had completed our site visits. Also, 

MNC-I could not confirm the location of the lids; the project was started before 

MNC-I’s civil affairs brigades had responsibility for the CERP projects at BIAP. 

Business Center Automation Contract 

Reported 

Cost: 

$89,000 

Outcome: Equipment Purchase Completed, Not Being Used as Intended 

Discussion: Initiated in November 2006, this project provided servers, local area networks, 

and other computer equipment for the business center facility. When we visited 

the project site in September 2009, the equipment had been removed from the 

building. A GOI official stated that the equipment was deliberately removed 

from the business center and relocated to the ICAA’s offices in the main terminal 

at BIAP. The official added that the GOI did not have funds to pay a 

management contractor to guard the facility, and had the equipment been left on 

site it would have been pilfered. Because the equipment was removed from the 

project site and currently is not being used as intended, the funds spent on the 

project constitute waste. 
62 

Business Center Furniture Contract 

Reported 

Cost: 

$82,804 

Outcome: Equipment Purchase Completed, Not Being Used as Intended 

Discussion: Initiated in November 2006, this project provided furniture for the business 

center facility. When we visited the project site in September 2009, the furniture 

had been removed from the building. A GOI official stated that the furniture was 

deliberately removed from the business center and relocated to the ICAA’s 

offices in the main terminal at BIAP. The official added that the GOI did not 

have funds to pay a management contractor to guard the facility, and had the 

furniture been left on site it would have been pilfered. Because the furniture was 

removed from the project site and currently is not being used as intended, the 

funds spent on the project constitute waste. 

Iraq Aviation Institute Facility Improvement 

Reported 

Cost: 

$79,735 

Outcome: Renovation Completed, Used Minimally 

Discussion: Initiated in April 2007, this project was to perform minor facility improvements 

such as install carpet, doors and windows, and electrical outlets; build 

administrative and food service counters; install signs; and improve landscaping 

at the Iraq Aviation Institute. When we visited the institute in September 2009, 

these improvements appeared to have been completed and maintained. Overall, 

the facility appeared to have been used minimally. 

USF-I did not agree with SIGIR’s assessment and said in its written comments 

that the institute is fully staffed and operational. SIGIR notes that its assessment 

reflects conditions at the time of our visit. 

Runway Lighting System 

Reported 

Cost: 

$72,856 

Outcome: Equipment Purchase Completed, Not Maintained 
63 

Discussion: Initiated in January 2008, the Runway Lights project purchased spare bulbs and 

parts to repair the BIAP taxiway and runway lighting system. The lights were 

installed, but due to electrical power fluctuations, many of the original lights 

burned out. According to an MNC-I official, the GOI spends approximately 

$50,000 per quarter replacing bulbs that continue to burn out. 

Engineer Retainer Contract I 

Reported 

Cost: 

$61,590 

Outcome: Minimal Evidence of Work Performed 

Discussion: MNC-I officials did not know the results of the work performed by Iraqi 

engineers hired on retainer contracts to assist contracting officers’ representatives 

with daily quality assurance and other quality checks. The engineers provided 

these services on projects such as the Caravan Hotel, which were executed by 

civil affairs brigades rather than GRD. MNC-I civil affairs personnel could not 

find evidence in the project files to verify whether the engineers had completed 

daily reports or had provided other feedback. The officials said that if the 

engineers had produced daily reports, the documentation would have been 

voluminous; thus, previous brigades may not have maintained the reports in the 

CERP project files after the projects were completed. Due to a lack of 

documented oversight, the funds spent on this project constitute potential waste. 

Business Center Security Building Rehabilitation 

Reported 

Cost: 

$31,250 

Outcome: Renovation Completed, Not Being Used 

Discussion: Initiated in November 2006, this project was to renovate an existing building 

adjacent to the Business Center facility to provide a security command center for 

the Business Center. When we visited the project site in November 2009, we 

noted that the building had not been maintained and was in a state of disrepair. 

For example, the entryway to the building was covered with broken glass, holes 

in external walls had not been repaired, and the floor was covered by trash and 

what appeared to be human feces. 
64 

Business Center Equipment Purchase 

Reported 

Cost: 

$24,315 

Outcome: Equipment Purchase Completed, Not Being Used as Intended 

Discussion: Initiated in April 2007, this project provided general support equipment such as a 

podium, microphone, and speakers for the Business Center facility. When we 

visited the project site in September 2009, the equipment had been removed from 

the building. A GOI official stated that the equipment was deliberately removed 

from the business center and relocated to the ICAA’s offices in the main terminal 

at BIAP. The official added that the GOI did not have funds to pay a 

management contractor to guard the facility and that had the equipment been left 

on site it would have been pilfered. Because the equipment was removed from 

the project site and was not being used as intended, the funds spent on the project 

constitute waste. 

Business Center Internet Service 

Reported 

Cost: 

$17,920 

Outcome: Service Partially Provided, Project Terminated 

Discussion: Initiated in October 2007, this project provided Internet service on a temporary 

basis to the Engineer Retainer Teams that used the service. The project was 

terminated in October 2008 when it was determined that the service was 

duplicative and no longer required. 

Iraq Aviation Institute Water Supply Pipe 

Reported 

Cost: 

$13,275 

Outcome: Construction Completed, Used Minimally 

Discussion: Initiated in November 2007, this project was to install a water supply pipe that 

would provide potable water to the Iraqi Aviation Institute and the Air Traffic 

Controller Training Center facilities. When we visited the project site in 

September 2009, the pipe appeared to be connected and functioning properly; 
65 

however, both facilities it supports are used minimally. 

USF-I did not agree with SIGIR’s assessment and said in its written comments 

that the institute is fully staffed and operational. SIGIR notes that its assessment 

reflects conditions at the time of our visit. 
66 

Appendix C—MNC-I’s Official Explanation of the 

Development Effort at BIAP 

During our audit, we met with senior U.S. Forces-Iraq officials formerly assigned to MNC-I 

when several of the BIAP projects were being planned and approved. The officials have 

extensive knowledge of the projects—for example, why certain decisions were made—that is not 

documented in the project files. We asked for written documentation of their knowledge of the 

BIAP projects. MNC-I provided comments, and U.S. Forces-Iraq approved our use of the 

comments in this report. The comments provide a historical context for the development effort 

at BIAP. We have referred to the comments throughout the discussion section of the report and 

are providing a copy of the comments in this appendix. 
67 
68 
69 
70 
71 
72 

Appendix D—Approval Dates and Disbursements for 

CERP Projects at BIAP 

Figure 14 illustrates a timeline, by quarter, for the BIAP project approvals and total 

disbursements as of November 22, 2009. 

Figure 14—Approval Dates by Fiscal Year Quarter and Disbursements as of 

November 22, 2009, for CERP Projects at BIAP 

Source: SIGIR analysis of CERP project file documentation as of 11/22/2009. 
73 

Appendix E—CERP Statutes 

Since CERP’s inception in 2003, the Congress has enacted a number of CERP-related public 

laws. Most of the laws have either authorized or appropriated funding for CERP and have 

consistently described the program as having been created 

for the purpose of enabling military commanders in Iraq to respond to urgent 

humanitarian relief and reconstruction requirements within their areas of 

responsibility by carrying out programs that will immediately assist the Iraqi 

people, and to fund a similar program to assist the people of Afghanistan. 

In addition to the Public Law number and title, Table 3 outlines, for various CERP statutes, the 

appropriation amount and the ending date for obligations for the respective appropriation. 

Table 3—CERP Statutes (FYs 2004 – 2009) 

Date Public Law Name Remarks 

Appropriation 

Amount 

End of 

Obligation 

Period 

Date 

FYa 2004 

11/6/2003 

P.L.b 108-

106, Title I, 

Section 

1110 

Emergency 

Supplemental 

Appropriations Act for 

Defense and for the 

Reconstruction of Iraq 

and Afghanistan, 

2004 

Set not to exceed 

$180 million (Total 

Commander’s 

Emergency 

Response Program) 

$180,000,000 9/30/2004 

FY 2005 

8/5/2004 

P.L. 108-

287, Title 

IX, Section 

9007 

Department of 

Defense 

Appropriations Act, 

2005 

Set not to exceed 

$300 million (Total 

Commander’s 

Emergency 

Response Program) 

$300,000,000 9/30/2005 

10/28/2004 

P.L. 108-

375, Title 

XII, Subtitle 

A, Section 

1201 

Ronald W. Reagan 

National Defense 

Authorization Act for 

Fiscal Year 2005 

Authorized not to 

exceed $300 million 

for FY2005 

N/A 
74 

Date Public Law Name Remarks 

Appropriation 

Amount 

End of 

Obligation 

Period 

Date 

12/8/2004 

P.L. 108-

447, 

Division J, 

Title I, 

Section 102 

Consolidated 

Appropriations Act, 

2005 

Increased not to 

exceed by $200 

million to $500 million 

(Total Commander’s 

Emergency 

Response Program) 

$500,000,000 9/30/2005 

5/11/2005 

P.L. 109-

13, Title I, 

Section 

1006 

Emergency 

Supplemental 

Appropriations Act for 

Defense, the Global 

War on Terror, and 

Tsunami Relief, 2005 

Increased not to 

exceed by $354 

million (from $500 

million to $854 

million) (Total 

Commander’s 

Emergency 

Response Program) 

$354,000,000 9/30/2005 

FY 2006 

12/30/2005 

P.L. 109-

148, Title 

IX, Section 

9007 

Department of 

Defense, Emergency 

Supplemental 

Appropriations to 

Address Hurricanes 

in the Gulf of Mexico, 

and Pandemic 

Influenza Act, 2006 

Set not to exceed at 

$500 million (Total 

Commander’s 

Emergency 

Response Program) 

$500,000,000 9/30/2006 

1/6/2006 

P.L. 109-

163, Title 

XII, Subtitle 

A, Section 

1202 

National Defense 

Authorization Act for 

Fiscal Year 2006. 

Authorized not to 

exceed $500 million 

for each FY2006 and 

FY2007 

N/A 

6/15/2006 

P.L. 109-

234, Title I, 

Chapter 2, 

Section 

1207 

Emergency 

Supplemental 

Appropriations Act for 

Defense, the Global 

War on Terror, and 

Hurricane Recovery, 

2006 

Added not to exceed 

$423 million (Total 

Commander’s 

Emergency 

Response Program) 

$423,000,000 12/31/2007

FY 2007 

9/29/2006 

P.L. 109-

289, Title 

IX, Section 

9006 

Department of 

Defense 

Appropriations Act, 

2007 

Set not to exceed 

$500 million (Total 

Commander’s 

Emergency 

Response Program) 

$500,000,000 9/30/2007 
75 

Date Public Law Name Remarks 

Appropriation 

Amount 

End of 

Obligation 

Period 

Date 

5/25/2007 

P.L. 110-

28, Title I, 

Chapter 3, 

Section 

1307 

U.S. Troop 

Readiness, Veterans’ 

Care, Katrina 

Recovery, and Iraq 

Accountability 

Appropriations Act, 

2007 

Added not to exceed 

$456.4 million (Total 

Commander’s 

Emergency 

Response Program) 

$456,400,000 9/30/2007 

12/26/2007 

P.L. 110-

161, Title 

VI, Section 

606 

Consolidated 

Appropriations Act, 

2008 

Set not to exceed 

$500 million (Total 

Commander’s 

Emergency 

Response Program) 

$500,000,000 9/30/2008 

FY 2008 

1/28/2008 

P.L. 110-

181, Title 

XII, Subtitle 

A, Section 

1205 

National Defense 

Authorization Act for 

Fiscal Year 2008 

Amended the 

National Defense 

Authorization Act for 

FY2006 by striking 

FY2006 and FY2007 

and inserting FY2008 

and FY 2009; 

authorized an 

increase of 

$447,441,000 not to 

exceed per fiscal 

year (from $500 

million to 

$977,442,000) 

N/A 

6/30/2008 

P.L. 110-

252, Title 

IX, Section 

9104 

Supplemental 

Appropriations Act, 

2008 

Set not to exceed at 

$1,226,841,000 $1,226,841,000 9/30/2008 

 
76 

FY 2009 

10/14/2008 

P.L. 110-

417, Title 

XII, Subtitle 

B, Section 

1214 

Duncan Hunter 

National Defense 

Authorization Act for 

Fiscal Year 2009 

Authorized an 

increase of 

$722,559,000 for 

FY2008, not to 

exceed a total of $1.7 

billion; authorized an 

increase of 

$552,559,000 for 

FY2009, not to 

exceed a total of $1.5 

billion 

N/A 

Total 

Appropriations 

$4,940,241,000 

Source: SIGIR analysis of Commander’s Emergency Response Program Statutes as of 1/4//2010. 

Notes: 

a

 Fiscal Year 

b

 Public Law 
77 

Appendix F—Permissible Categories of CERP Fund 

Usage 

The MAAWS, dated January 26, 2009 (with Change 2, dated November 1, 2009), allows CERP 

funds to be used under 20 broad categories of assistance. Overall, the categories have remained 

fairly constant since the initial CERP guidance was published in June 2005. 

1. Agriculture/Irrigation: Projects to increase agricultural production or cooperative 

agricultural programs. 

2. Battle Damage Repair: Projects to repair, or make payments for repairs of, property damage 

that results from U.S., coalition, or supporting military operations and is not compensable 

under the Foreign Claims Act. 

3. Civic Cleanup Activities: Projects to clean up public areas; area beautification. 

4. Civic Support Vehicles: Projects to purchase or lease vehicles by public/government 

officials in support of civic and community activities. 

5. Condolence Payments: Payments to individual civilians for the death or physical injury 

resulting from U.S., coalition, or supporting military operations not compensable under the 

Foreign Claims Act. 

6. Economic, Financial, and Management Improvements: Projects to improve economic or 

financial security. 

7. Education: Projects to repair or reconstruct schools or to purchase school supplies or 

equipment. 

8. Electricity: Projects to repair, restore, or improve electrical production, distribution, and 

secondary distribution infrastructure. Cost analysis must be conducted so the village or 

district may collect revenues to ensure operation and maintenance of the system for longterm use. 

9. Food Production & Distribution: Projects to increase food production or improve 

10. ] distribution processes to further economic development. 

11. Former Detainee Payments: Payments to individuals upon release from Coalition (nontheater internment) detention facilities. 

12. Healthcare: Projects to repair or improve infrastructure, equipment, medical supplies, 

immunizations, and training of individuals and facilities in respect to efforts made to 

maintain or restore health, especially by trained and licensed professionals. 
78 

13. Hero Payments: Payments made to the surviving spouses or next of kin of Iraqi defense or 

police personnel who were killed as a result of U.S., coalition, or supporting military 

operations. ([These were] previously referred to as Martyr payments in Iraq.) 

14. Other Urgent Humanitarian or Reconstruction Projects: Projects to repair collateral damage 

not otherwise payable because of combat exclusions or condolence payments. Other urgent 

humanitarian projects not captured under any other category. For other urgent humanitarian 

projects, this category should be used only when no other category is applicable. 

15. Protective Measures: Projects to repair or improve protective measures to enhance the 

durability and survivability of a critical infrastructure site (oil pipelines, electric lines, et 

cetera). 

16. Repair of Civic and Cultural Facilities: Projects to repair or restore civic or cultural 

buildings or facilities. 

17. Rule of Law and Governance: Projects to repair or reconstruct government buildings such as 

administrative offices or courthouses. 

18. Telecommunications: Projects to repair or extend communication over a distance. The term 

telecommunication covers all forms of distance and/or conversion of the original 

communications, including radio, telegraphy, television, telephony, data communication, and 

computer networking. Includes projects to repair or reconstruct telecommunications systems 

or infrastructure. 

19. Temporary Contract Guards for Critical Infrastructure: Projects including Sons/Daughters of 

Iraq and others to guard critical infrastructure, including neighborhoods and other public 

areas. 

20. Transportation: Projects to repair or restore transportation to include infrastructure and 

operations. Infrastructure includes the transportation networks (roads, railways, airways, 

canals, pipelines, et cetera) that are used, as well as the nodes or terminals (such as airports, 

railway stations, bus stations, and seaports). The operations deal with the control of the 

system, such as traffic signals and ramp meters, railroad switches, air traffic control, et 

cetera. 

21. Water & Sanitation: Projects to repair or improve drinking water availability, to include 

purification and distribution. Building wells in adequate places is a way to produce more 

water, assuming the aquifers can supply an adequate flow. Other water sources such as 

rainwater and river or lake water must be purified for human consumption. The processes 

include filtering, boiling, and distillation among more advanced techniques, such as reverse 

osmosis. The distribution of drinking water is done through municipal water systems or as 

bottled water. Sanitation, an important public health measure that is essential for the 

prevention of disease, is the hygienic disposal or recycling of waste materials, particularly 

human excrement. 
79 

Appendix G—Acronyms 

Acronym Description 

BEZ Baghdad International Airport Economic Zone 

BIAP Baghdad International Airport 

CERP Commander’s Emergency Response Program 

DoD U.S. Department of Defense 

DoS U.S. Department of State 

FY fiscal year 

GOI Government of Iraq 

ICAA Iraq Civil Aviation Authority 

MAAWS Money as a Weapon System 

MNC-I Multi-National Corps-Iraq 

MOT Ministry of Transportation 

P.L. Public Law 

SIGIR Special Inspector General for Iraq Reconstruction 

USAID U.S. Agency for International Development 
80 

Appendix H—Audit Team Members 

This report was prepared and the audit conducted under the direction of David R. Warren, 

Assistant Inspector General for Audits, Office of the Special Inspector General for Iraq 

Reconstruction. 

The staff members who conducted the audit and contributed to the report include: 

Paula A. Braun 

Arthur Granger 

Milton L. Naumann 

Nancee K. Needham 
81 

Appendix I—Management Comments and Audit 

Response 

The following comments were provided by U.S. Forces-Iraq. 
82 

 
83 

U.S. FORCES-IRAQ 

COMMAND REPLY 

to 

SIGIR Draft Audit Report – Commander’s Emergency Response Program: Projects at 

Baghdad Airport Provided Some Benefits, but Waste and Management Problems 

Occurred 

SIGIR Report Number 10-013 

SIGIR Project 9026

1. Draft Report Summary Page. There are several references to MNC-I in the present tense. 

Command Comment. All present time and forward references to the former command 

headquarters (MNC-I, MNF-I, MNSTC-I, etc.) should be changed to USF-I. 

SIGIR Response. SIGIR added wording in the background section of the report clarifying how 

responsibility for the projects shifted from MNC-I to USF-I. However, in the report we continue 

to refer to MNC-I and MNF-I as these were the organizations that approved and implemented 

these projects. 

2. Draft Report Summary Page. The report states that “To MNC-I’s credit, it is actively 

working with the GOI, who now has ownership...” 

Command Comment. Recommend changing MNC-I to USF-I and specifically detailing who in 

GOI should have ownership of this opportunity to gain additional benefits from the investment 

that has been made. 

SIGIR Response. As discussed in comment 1, SIGIR added wording in the background section 

of the report clarifying how responsibility shifted from MNC-I to USF-I. 

SIGIR also believes that USF-I is in the best position to determine which GOI officials are in the 

best position to help it facilitate the use of the BIAP projects. 

3. Draft Report Summary Page. The report states that SIGIR also notes that project risk and 

outcomes were also impacted by (1) the inherent difficulties in undertaking projects in a war 

zone; and (2) difficulties in working with...” 

Command Comment. Recommend specifically addressing the surge of U.S. Forces during the 

period of this project as amplification to the “war zone” reference. The surge of U.S. Forces 

under the direct control of MNC-I at the time of this project greatly complicated the command’s 

on-going CERP foci. Additionally, several projects were extended in duration in direct support 

of the surge forces positioned on BIAP in coordination with the GOI. 

 
84 

SIGIR Response. SIGIR added language in the executive summary, the background section, the 

section discussing SIGIR’s analysis of the cause, and in the conclusion section explaining USFI’s position regarding the importance of the projects to the 2007-2008 surge in U.S. forces, and 

how MNC-I’S focus on the surge affected its oversight of the projects. 

4. Draft Report Summary Page. The report states that, “While this may be appropriate for 

small-scale CERP projects this is not the case for large-scale efforts with multiple integrated...” 

Command Comment. Recommend specifically addressing that CERP is no-longer used for 

large-scale efforts; this change was already made. 

SIGIR Response: SIGIR continues to believe that guidance for large scale projects is still 

needed because, while the approval requirements for CERP projects have been strengthened, it is 

still possible to execute projects over $1 million if approved by the Secretary of Defense. Also, 

to the extent that DoD is involved in stabilization and reconstruction operations in Iraq and in 

other theaters, the possibility that other large-scale projects may be undertaken remains. Lastly, 

it is also possible to initiate multiple related projects that could have a combined value in the 

millions of dollars, as happened with the BIAP projects. 

5. Page 2, first sentence in second paragraph under title “Overarching Rationale and 

Approach to Projects.” The report states that “The CERP projects were approved in phases 

from February 2005 through February 2008.” 

Command Comment: Recommend validating the start date for BIAP CERP projects, as 2005 

may be incorrect. 

SIGIR Response: SIGIR found that MNC-I information showed that the earliest projects were 

initiated in February 2005. SIGIR included these projects in its analysis because they were 

intended to facilitate airport certification. 

6. Page 2, last sentence in second paragraph under title “Overarching Rationale and 

Approach to Projects.” The report states that “These projects included renovation of an 

existing cargo terminal and the Iraq Aviation Institute; new construction of the Air Traffic 

Controller Training Center; and various other service, equipment, and utility projects.” 

Command Comment. Recommend that this paragraph include the fact that many of the 

planned projects were impacted by the requirement to utilize existing property and infrastructure 

at BIAP to facilitate the U.S. forces designated for the surge, which included an aviation brigade. 

SIGIR Response. SIGIR added the recommended language to the report. 

 
85 

7. Page 4, Introduction Comments. “These brigades were responsible for initiating, executing, 

etc.” 

Command Comment. USF-I updated information on the departure date of the 364th Civil 

Affairs Brigade. 

SIGIR Response. SIGIR added the updated information to this report. 

8. Page 4, last sentence in first partial paragraph. The report states that “The ICAA and Iraqi 

Airways share ownership of all facilities at the airport.” 

Command Comment. This is not factual. In fact, they share only designated facilities. 

SIGIR Response. SIGIR agrees, and this report contains this change. 

9. Page 5, The Majority of Projects Achieved Benefits, etc. As of November 2009, MNC-I 

had approved and initiated 46 individual CERP projects at BIAP etc. 

Command Comment. USF-I concurs with the information provided in the report. 

SIGIR Response. No response required. 

10. Page 5, The Majority of Projects Achieved Benefits, but Significant Investments 

Remain at Risk of Waste. “About $16 million (46%) was used for 24 projects that resulted in 

outcomes with questionable value; etc. 

Command Comment. USF-I partially concurs with information provided in the report. We 

generally concur that there were problems or incomplete work on these projects, but will note 

areas of no concurrence on specific projects separately. 

SIGIR Response. No response required. SIGIR will comment on the areas of disagreement in 

comments 31 to 38. 

11. Page 5, fifth sentence in third paragraph under title “The Majority of Projects 

Achieved Benefits, etc.” “The questionable outcome projects include projects that, at present, 

are not being used, etc.” 

Command Comment. The report should reflect that, at present, the decisions to use, not 

maintain, use minimally, or use differently than intended, or terminate are decisions made by the 

GOI, not the USF-I. 

SIGIR Response. SIGIR has added a discussion of this issue in this report’s section on CERP 

guidance. In general, SIGIR’s position is that Iraq reconstruction efforts extend beyond brick 

and mortar construction to include providing the Iraqis with viable resources that improve their 

lives and environment. To achieve these results, SIGIR has previously reported on the 

importance of ensuring that reconstruction projects are consistent with the needs of the host 

government and that the host government has the capacity to maintain them. While MNC-I may 
86 

not be in a position to develop the GOI’s capacity, these projects were built with MNC-I’s CERP 

funding, and thus we believe that MNC-I had the responsibility to help ensure that these 

elements of planning were addressed. The current MAAWS guidance now addresses this issue. 

12. Page 5, first sentence in fourth paragraph under title “The Majority of Projects 

Achieved Benefits, etc.” “We acknowledge the overall MNC-I rationale for the BIAP projects 

was to reduce violence and to support the objectives of the military surge.” 

Command Comment. The report should reflect that several facilities and significant apron 

space were used on BIAP to facilitate the additional U.S. 3rd Combat Aviation Brigade, which 

was part of the initial surge force package in 2007. An additional rationale for the BIAP projects 

was in acknowledgement for the use of these facilities and space. 

SIGIR Response. SIGIR has added this information to the background section. 

13. Page 16, last sentence in first bulletized paragraph under title “Convention Center.” 

After nearly $5 million was spent, the contract was terminated for default in November 2008, 

etc.” 

Command Comment. The report should reflect that the MNC-I headquarters that initiated the 

convention center contract executed a Transition of Authority (TOA) on February 14, 2008. The 

subsequent assessment of the contract that led to termination was executed by this new 

headquarters. 

SIGIR Response. SIGIR notes this information in this report. 

14. Page 18, third sentence in first paragraph under title “Incinerator.” “The project was 

transferred to the ICAA.” 

Command Comment. The report should attribute the September 28, 2009 observation of an 

empty fuel tank and infrequent use to the ICAA, as ICAA had ownership of the incinerators 

since May 2008. 

SIGIR Response. SIGIR did not change the report to address this comment. As discussed in 

the report, SIGIR considers a project undertaken and given to the Iraqis that is not being used as 

money wasted. 

15. Page 21, first bulletized paragraph under title “Inadequate planning, Staff Rotation, 

and Guidance led to Questionable Outcomes.” “The projects were undertaken without a plan 

to guide the effort, and without adequate coordination with U.S. civilian agencies.” 

Command Comment. The report should specifically address that coordination was made by 

MNC-I with the U.S. Embassy’s Transportation Attaché. 
87 

SIGIR Response. SIGIR added the fact that USF-I officials stated that MNC-I coordinated with 

the Transportation Attaché to the report. However, as noted in the report this coordination is not 

documented nor are any agreements reached as to the roles and responsibilities of each party. 

16. Page 21, fourth bulletized paragraph under title “Inadequate Planning, Staff Rotation, 

etc.” “MNC-I personnel assigned to the projects lacked expertise in large-scale development 

projects, etc.” 

Command Comment. The report should specifically address that the civil affairs brigade 

assigned to MNC-I through Transfer of Authority on February 14, 2008 had the necessary 

expertise to manage the BIAP CERP projects. After the transfer of the civil affairs brigade who 

originally managed the project, the expertise may have been reduced, leading up to the projects 

termination in November 2008. 

SIGIR Response. SIGIR notes this information in this report. 

17. Page 21, paragraph under “Inadequate Planning, Staff Rotation, and Guidance, etc.” 

“Project files were not well maintained and project tracking data was incomplete.” 

Command Comment. USF-I partially concurs with information provided in the report. It is 

true that project files were not well maintained and that project tracking data was incomplete. 

This, however, does not continue to be a long-standing problem. We have gone through all files 

of every project and have a comprehensive paper and electronic filing system for every project. 

There are still missing documents, however, not nearly as many as in the past and the files are 

more complete than not. 

SIGIR Response. SIGIR notes this information in this report. 

18. Page 21, MNC-I Did Not Develop a Comprehensive Plan for the BIAP Projects. 

“MNC-I did not develop a command-approved master plan that included specific goals, 

objectives, etc.” 

Command Comment. USF-I partially concurs with information provided in the report. Though 

it could have been more detailed, USF-I did in fact provide a BIAP master plan and conducted 

several briefs regarding the master plan. Additionally, the master plan in part drove some of the 

project development decisions during the course of construction. For example, the BIAP 

Caravan Hotel was originally a temporary structure designed to provide modest temporary 

billeting for transient personnel as a direct result of the BIAP Economic Zone master plan; the 

hotel increased from fifty to one hundred rooms and acquired a restaurant, central air 

conditioning, a lobby and became a three star hotel to accommodate the BIAP master plan. 

SIGIR Response. SIGIR notes in this report USF-I’s position assertion that it had a master plan. 

However, as SIGIR stated in the report, we saw a number of documents related to the projects at 

BIAP. However, in SIGIR’s judgment none of these documents contained the traditional 

elements of a project plan, nor did they contain any indication that they had been reviewed or 
88 

approved by MNC-I officials at any level. As such, SIGIR does not consider these documents to 

be plans. 

19. Page 22, last sentence in third paragraph under title “CERP Guidance Does Not 

Require Comprehensive Plans for Related Projects.” “Some areas identified in the handbook 

that may require planning include the following:” 

Command Comment. Recommend the word “may” be changed to “should” as the GOI through 

the help of the U.S. Department of State Embassy Transportation Attache, should plan the 

enumerated areas that follow this sentence. 

SIGIR Response. In this report, SIGIR uses the word “should” and notes USF-I’s position that 

it was up to the GOI, with the help of the U.S. Embassy’s Transportation Attaché to do this 

planning rather than MNC-I. Nonetheless, these projects were undertaken with MNC-I’s CERP 

funding, and thus SIGIR believes that MNC-I had the responsibility to ensure that these elements 

of planning were addressed. 

Additionally, the separation of economic development responsibilities between the Department 

of Defense and civilian agencies illustrates SIGIR’s long-standing concern that a lack of unity of 

command can be a primary contributor to inefficiency, ineffectiveness, and waste in Iraq 

reconstruction programs. 

20. Page 23, last sentence of first full paragraph. The report states that, “...the document did 

not discuss such factors as clearly defined boundaries for the zone, permitted and prohibited 

activities within the zone, and other economic benefits for investors, such as exemptions from 

taxes or fees.” 

Command Comment. Recommend that the report properly annotate that these enumerated 

factors were within GOI’s responsibility to define, not MNC-I’s. 

SIGIR Response. SIGIR agrees that these factors are within GOI’s responsibility to define. 

But, at the same time they are important planning factors in developing an economic zone. For 

example, economic zones usually have restricted access. Nowhere in the documents SIGIR 

reviewed were boundaries, boundary security, or access issues discussed. Also, SIGIR points 

out in the report that the Baghdad International Airport is not designated as a free trade zone 

under Iraqi law, and unless the Iraqis change their law it will not be an economic zone. This 

raises questions about what exactly the planning factors for the project were and what 

coordination occurred. Overall, this supports SIGIR’s findings that 1) the project was not 

undertaken as an integrated project, but rather as 46 independent projects, and 2) that the 

planning and coordination for the effort was inadequate and contributed to an unsuccessful 

outcome for a large number of projects. 
89 

21. Page 23, first sentence in first paragraph under title, “Project Coordination Was 

Informal and Not Well Documented.” The report states that, “...with representatives from the 

U.S. Agency for International Development and DoS.” 

Command Comment. Recommend that the sentence specify the Embassy Transportation 

Attaché in the reference to DoS. Additionally, recommend the report annotate that MNC-I 

officials who were responsible for program management directly briefed the deputies of several 

GOI ministries, the Prime Minister, and the Chief of Mission in January 2008. This was 

immediately prior to MNC-I transition between headquarters and designed to ensure continued 

GOI involvement in the progress of the BIAP economic zone. 

SIGIR Response. SIGIR notes in this report information on the many people that MNC-I said 

they coordinated with. However, SIGIR also notes that any agreements reached with either the 

GOI or other U.S. reconstruction agencies were not documented. As a result, no basis exists to 

determine project responsibilities and for assigning accountability for accomplishing those 

responsibilities. 

22. Page 23, first sentence in the second paragraph under title “Project Coordination Was 

Informal and Not Well Documented.” The report states that, “The MAAWS in use when the 

projects were undertaken required MNC-I to coordinate CERP projects with local GOI 

agencies...” 

Command Comment. Recommend the sentence specify that MNC-I directly coordinate this 

CERP project with ITAO within GOI. 

SIGIR Response. SIGIR has no comment. 

23. Page 24, first sentence of first full paragraph. The report states that, “At the request of 

MNSTC-I...” 

Command Comment. Recommend that “MNSTC-I” be changed to “USF-I officials.” 

SIGIR Response. In this report SIGIR uses “USF-I officials.” 

24. Page 24, third full paragraph. The report states that, “USAID officials we 

interviewed...waste in the Iraq reconstruction program.” 

Command Comment. Recommend that the paragraph include MNC-I’s specific collaboration 

with Task Force Brinkley (under the Office of the Secretary of Defense) for the BEZ and the 

hotel collaboration therein. 

SIGIR Response. SIGIR notes this information in this report. 

25. Page 24, first sentence in the first paragraph under title “Measures to Assess Project 

Effectiveness Were Not Developed.” The report states that, “MNC-I did not attempt to 
90 

measure the economic impact of the CERP projects at BIAP or to determine whether the projects 

had a direct impact on the level of violence or economic development in Iraq.” 

Command Comment. Recommend that the report include factual information that the last 

indirect fire attack on or in the vicinity of the BEZ was May 2007. 

SIGIR Response. SIGIR added the requested information. 

26. Page 26, last sentence in the first full paragraph under title “Lack of Expertise and 

Frequent Turnover of Personnel Led to Inefficiencies.” The report states that, “After their 

tours ended, they said that they believed that the CERP projects at BIAP suffered a “lack of 

command emphasis.” 

Command Comment. Recommend that a time reference be added to this statement, or that the 

opined “lack of command emphasis” be described as “varied due to command changes in MNC-I 

and the supporting civil affairs brigade.” 

SIGIR Response. SIGIR notes this information in this report. 

27. Page 26, third full paragraph under the title “Lack of Expertise and Frequent 

Turnover of Personnel Led to Inefficiencies.”

Command Comment. This entire paragraph refers to a completely different issue than that 

which is defined in the scope of the report. The topic is both outside the scope and the U.S. 

Army Vice Chief of Staff comments about COR training were made more than two years after 

the BEZ to which this project refers. Recommend deleting this paragraph altogether. 

SIGIR Response. SIGIR believes that the discussion is relevant to the issues discussed in this 

report. SIGIR discusses this point in the “Lack of Expertise and Frequent Turnover of Personnel 

Led to Inefficiencies” section of the report. The contracting officers’ representatives who are 

responsible for overseeing project activities typically come from program office staff. For these 

projects, the various civil affairs brigades were the program office, and the ability of their 

personnel to effectively oversee and manage the projects would have been an important factor in 

the projects’ success. Since 24 of 46 projects had unsuccessful outcomes we believe that there 

were problems with the oversight of the projects. Further, the need for better training for 

contracting officers’ representatives has been identified in numerous reports including the 

Army’s Gansler Commission report.”17 

28. Page 28, Conclusions, Recommendations, and Lessons Learned. Recommendation 1. 

The Secretary of Defense should direct the Under Secretary of Defense (Comptroller) to revise 

CERP guidance to include a requirement that a project implementation plan be developed for 

large-scale projects. 

 

17 Urgent Reform Required: Army Expeditionary Contracting; Report of the “Commission on Army Acquisition 

and Program Management in Expeditionary Contracting,” Oct. 31, 2007. 
91 

Command Comment. Recommend that this recommendation be deleted as it is no longer 

applicable. There are no CERP-funded large-scale projects. The recommendation is dated. 

SIGIR Response. SIGIR continues to believe its recommendation has merit and is including it 

in this report. While the approval requirements for CERP projects have been strengthened, it is 

still possible to execute projects over $1 million if approved by the Secretary of Defense. Also, 

to the extent that DoD is involved in stabilization and reconstruction operations in Iraq and in 

other theaters, the possibility that other large-scale projects may be undertaken remains. Lastly, 

it is also possible to initiate multiple related projects that could have a combined value in the 

millions of dollars, as happened with the BIAP projects. Planning for these types of projects 

remains a requirement that should be addressed in DoD guidance. 

29. Page 28, Conclusions, Recommendations, and Lessons Learned, Recommendation 2. 

The Commanding General, U.S. Forces-Iraq, should take actions to enhance its data systems 

used to track and record CERP-project data. 

Command Comment. USF-I J7, in coordination with the USDs, is currently scrubbing and 

correcting the CERP information in the Iraq Reconstruction Management System. The objective 

is to complete the update prior to the shut-down of the system. USF-I J7 will provide data to 

users until September 1, 2010 and is presently evaluating data-tracking mechanisms for after 

September 1, 2010. 

SIGIR Response. SIGIR has no response as USF-I concurred with the recommendation. 

30. Page 30, Appendix A-Scope and Methodology 

Command Comment: USF-I concurs with the information provided. 

SIGIR Response. SIGIR has no response as USF-I concurs with the information. 

Comments 31 to 38. USF-I did not agree with SIGIR’s conclusion that 6 of the 24 projects 

we identified as having unsuccessful outcomes were deficient. These projects were: 

• Cargo Terminal Refurbishment 

• Iraq Aviation Institute Rehabilitation 

• Iraq Aviation Institute Automation Contract 

• Iraq Aviation Institute Furniture Purchase 

• Iraq Aviation Institute Facility Improvement 

• Iraq Aviation Institute Water Supply Pipe 

Command Comments. USF-I provided comments on six projects that disagreed with SIGIR’s 

inspection findings. 

SIGIR Response. SIGIR addresses each of USF-I’s comments in detail in Appendix B of this 

report. Overall, SIGIR’s assessments remain unchanged since it reflects our findings at the time 
92 

of our site visits. Subsequent improved use of the projects is consistent with SIGIR’s 

recommendation to maximize the benefits of the investment. USF-I has offered to provide 

support for its position, and SIGIR has requested that support. 

39. Page 51, Appendix C-MNC-I’s Official Explanation of the Development Effort at BIAP

Command Comment. USF-I concurs with the information. 

SIGIR Response. SIGIR has no response as USF-I concurs with the information. 
93 

Appendix J—SIGIR Mission and Contact Information 

SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, and 

operations in Iraq, the Special Inspector General for Iraq 

Reconstruction provides independent and objective: 

• oversight and review through comprehensive audits, 

inspections, and investigations 

• advice and recommendations on policies to promote 

economy, efficiency, and effectiveness 

• deterrence of malfeasance through the prevention and 

detection of fraud, waste, and abuse 

• information and analysis to the Secretary of State, the 

Secretary of Defense, the Congress, and the American 

people through Quarterly Reports 

Obtaining Copies of SIGIR 

Reports and Testimonies 

To obtain copies of SIGIR documents at no cost, go to 

SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, and 

Abuse in Iraq Relief and 

Reconstruction Programs 

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

• Web: www.sigir.mil/submit_fraud.html 

• Phone: 703-602-4063 

• Toll Free: 866-301-2003 

Congressional Affairs Hillel Weinberg 

Assistant Inspector General for Congressional 

 Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1059 

Email: hillel.weinberg@sigir.mil 

Public Affairs Danny Kopp 

Office of Public Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1217 

Fax: 703-428-0818 

Email: PublicAffairs@sigir.mil